G.R. No. L-40639 November 23, 1976
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ISIDRO (BOY) BUSCATO and NESTOR DALUD, defendants-appellants.

FACTS

The case originated from the stabbing death of Rodolfo Lim on January 13, 1973, in Sultan Kudarat, Cotabato. Appellants Isidro Buscato and Nestor Dalud, along with Jabib Tan, were convicted of Robbery with Homicide by the Court of First Instance and sentenced to reclusion perpetua. The prosecution’s case heavily relied on the extrajudicial confessions allegedly executed by Dalud and Tan, which implicated Buscato as the one who stabbed the victim and Dalud as having struck him. The confessions stated the motive was to rob Lim of money he was to collect. The appellants repudiated these confessions, testifying they were extracted through force, violence, and intimidation by Philippine Constabulary soldiers. Buscato specifically recounted being maltreated from January 15 to 18, 1973. The trial court found the confessions voluntary, noting the affiants did not present medical certificates or file charges against their alleged tormentors.

ISSUE

The core issue is whether the extrajudicial confessions of the appellants were voluntarily given and admissible as evidence to sustain their conviction for Robbery with Homicide.

RULING

The Supreme Court reversed the conviction and acquitted the appellants. The legal logic centered on the constitutional right against self-incrimination and the requirement that confessions must be free and voluntary. The Court meticulously examined the circumstances surrounding the confessions. It found the appellants’ claims of maltreatment credible, particularly in light of the Acting Solicitor General’s own manifestation recommending acquittal due to the prosecution’s failure to prove the confessions’ voluntariness. The Court emphasized that the burden to prove voluntariness lies with the prosecution, which it failed to discharge. The appellants’ repudiation, coupled with the lack of convincing rebuttal evidence from the state, created reasonable doubt. The Court invoked the principle that any confession obtained through force or intimidation is inadmissible, as it violates the fundamental right to due process. Without these inadmissible confessions, the remaining circumstantial evidence was insufficient to establish guilt beyond reasonable doubt. The constitutional presumption of innocence therefore prevailed. The Court ordered a copy of the decision furnished to the Secretary of Justice for possible action against those responsible for the alleged maltreatment.