G.R. No. 95850 November 18, 1991
The People of the Philippines, plaintiff-appellee, vs. Renee Parojinog y Namuag, et al., accused; Renee Parojinog y Namuag, accused-appellant.
FACTS
Accused-appellant Renee Parojinog, along with multiple co-accused, was charged with triple murder for the ambush of a combined INP-PC patrol in Ozamiz City on March 31, 1984, which resulted in the deaths of three lawmen. The information alleged conspiracy, treachery, and the aggravating circumstance of band. Parojinog pleaded not guilty, and trial proceeded solely against him as his co-accused remained at large. The prosecution’s case hinged primarily on his extra-judicial confession.
During the investigation on August 1, 1987, Parojinog confessed to being an NPA member and participating in the ambush. He was assisted by counsel from the CLAO, Atty. Fernando Fuentes III, after being informed of his constitutional rights. The trial court convicted him of a single complex crime of murder and imposed an indeterminate penalty. On appeal, the Court of Appeals affirmed the conviction but modified the penalty, sentencing him to three penalties of reclusion perpetua for three separate murders, and certified the case to the Supreme Court for review.
ISSUE
The primary issue is whether the extra-judicial confession of the accused-appellant is admissible and sufficient to sustain his conviction for three counts of murder.
RULING
The Supreme Court affirmed the conviction with modifications. The Court upheld the admissibility of Parojinog’s extra-judicial confession. The legal logic is that the confession was obtained in full compliance with constitutional safeguards. He was duly informed of his rights to remain silent and to counsel, and he was competently assisted by a lawyer, Atty. Fuentes, throughout the entire investigation process. This valid waiver and assistance rendered the confession voluntary and admissible as evidence.
The confession itself was detailed, admitting his NPA membership, participation in the 23-person ambush, and knowledge of the casualties. His defense of alibi was correctly rejected as inherently weak and could not prevail over his own positive and voluntary admission. His act of surrendering to the provincial governor in connection with the ambush further corroborated the confession’s veracity. Consequently, the confession, being credible and uncontroverted, provided sufficient basis to prove his guilt beyond reasonable doubt for the three murders. The Court modified the penalty to three separate penalties of reclusion perpetua and increased the civil indemnity to P50,000.00 for each victim.
