G.R. No. 77116 . January 31, 1989.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FERDINAND CAMALOG and NOVELITO SOTTO, defendants-appellants.

FACTS

Accused Armando de los Reyes, Ferdinand Camalog, and Novelito Sotto were charged with Robbery with Homicide for the killing of Jose Malabanan and the taking of cash and jewelry. The prosecution’s case initially relied heavily on the extra-judicial confessions of all three accused, which were sworn to before a municipal judge. De los Reyes, after being arrested based on a tip, confessed and implicated two companions named “Mario” and “Ben,” leading police to the Luneta Park where he pointed to Camalog and Sotto. The latter two were then arrested and also executed confessions.
During trial, de los Reyes recanted his confession, testifying that it was extracted through force and threats, and that he was coerced into implicating Camalog and Sotto, who were not his actual companions. Camalog and Sotto likewise repudiated their confessions, alleging they were tortured, not informed of their constitutional rights, and forced to sign the prepared statements. They presented alibi defenses corroborated by witnesses. The prosecution later presented a new eyewitness, Rodolfo Alabado, who surfaced over a year after the crime and identified the appellants.

ISSUE

The core issue is whether the extra-judicial confessions of appellants Camalog and Sotto are admissible and sufficient to sustain their conviction for Robbery with Homicide.

RULING

The Supreme Court reversed the conviction and acquitted Camalog and Sotto. The Court ruled the extra-judicial confessions inadmissible. For a confession to be valid, it must be voluntary, made with the assistance of competent and independent counsel, and the accused must be fully informed of their constitutional rights. The appellants’ detailed testimonies regarding the physical abuse and threats they endured to extract the confessions remained unrebutted by the prosecution. The mere fact that the confessions were sworn to before a judge does not cure their inherent defect if the voluntariness was vitiated by coercion at the initial police interrogation stage.
With the confessions rendered inadmissible, the remaining evidence was insufficient for conviction. The testimony of the late-presented eyewitness, Rodolfo Alabado, was deemed highly suspicious and unreliable due to his unexplained delay in coming forward and the circumstances of his being brought to court by the victim’s father. The Court noted the prosecution’s failure to present its original witness, Bayani Bocalan, giving rise to an adverse presumption. Consequently, without the confessions and with the alibi and denial of the appellants, the prosecution failed to prove their guilt beyond reasonable doubt. The acquittal was ordered immediately executory.