G.R. No. 92416 October 13, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JEFFREY LOGRONIO, accused-appellant.

FACTS

Jeffrey Logronio was accused, tried, and convicted by the Regional Trial Court for the crime of robbery with homicide and sentenced to reclusion perpetua. The information alleged that on the evening of December 26, 1986, in Manito, Albay, Logronio, with intent to gain, took assorted articles and cash from the store of Felisa Daen, and on the occasion thereof, by boxing and strangulating her, caused her death. The prosecution’s evidence, as summarized by the Solicitor-General, established that after the crime was reported, police investigation led to Logronio. He was found in Barangay Balasbas and, after initially denying involvement, admitted to the robbery and killing. He led the police to where he buried the loot (money totaling P304.00 wrapped in a T-shirt), which was recovered. At the police station, after being informed of his constitutional rights and assisted by Atty. Salvador Silerio, he executed an extrajudicial confession (Exhibit A) detailing how he hid in the victim’s house, robbed the store, and boxed the victim when she woke up. This confession was signed by Logronio and his counsel but was left unsubscribed as it was a holiday. During trial, Logronio repudiated his confession, testifying that he was forced at gunpoint by Rafael Dado, Jr. to witness the crime committed by Dado and Allan Magayanes, and that he confessed due to death threats from Magayanes. The trial court found his repudiation unworthy of belief.

ISSUE

The basic issue is the admissibility of Logronio’s written extrajudicial confession (Exhibit A). Specifically, whether it was inadmissible because: (a) it was not voluntarily executed; (b) he was not assisted by counsel during custodial investigation; (c) he was not meaningfully apprised of his rights; and (d) it was not subscribed or sworn to before an officer authorized to administer oaths.

RULING

The Supreme Court affirmed the trial court’s decision, with the modification of increasing the civil indemnity to P50,000.00. The Court held that the extrajudicial confession was admissible and voluntarily given. Logronio did not claim physical maltreatment by police but alleged intimidation by a civilian, which the Court found insufficient to vitiate his consent, especially as he had opportunities to complain but did not. He was assisted by counsel, Atty. Salvador Silerio, throughout the investigation, and the confession was signed by both. He was meaningfully apprised of his constitutional rights, as the police informed him of his right to remain silent and to counsel, and he waived these rights in writing and in the presence of his counsel. The confession’s lack of subscription before an oath-administering officer did not render it inadmissible, as the essential requirements of voluntariness and assistance of counsel were present. The Court also found Logronio’s repudiation and alternative story inherently unbelievable and contrary to human experience. Thus, the confession was properly admitted and supported his conviction.