G.R. No. L-11815; January 31, 1961
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PAMPILO DE TORRES, defendant-appellant.

FACTS

The accused, Pampilo de Torres, was convicted of murder for the killing of Simplicio Alcantara. The incident occurred in the early morning of May 15, 1954, in Calauan, Laguna. The victim, while walking home with two companions, was ambushed and shot multiple times, resulting in his death. The assailant was not seen during the attack. Two months later, the accused, a member of the Hukbalahap, was wounded and captured in an encounter in Lipa, Batangas. While confined in a hospital, he executed a sworn confession (Exhibit C) before a Justice of the Peace, admitting to the ambush. This confession incorporated a prior letter (Exhibit D) he had written, stating “Ako si Filo ang pumatay” and detailing his motive of jealousy over a woman named Gervacia. The defense contended the confession was coerced through a promise of leniency—specifically, that he would only be charged with simple rebellion instead of rebellion complexed with murder—and asserted an alibi that he was in the mountains of Lipa at the time of the killing.

ISSUE

The core issue is whether the extrajudicial confession (Exhibit C) of the accused is admissible and sufficient to sustain his conviction for murder, considering the defense’s claims that it was obtained through an improper inducement and lacks the required corroboration.

RULING

The Supreme Court affirmed the conviction, upholding the admissibility and sufficiency of the confession. The Court ruled that the confession was voluntarily given. The appellant ratified it under oath before a Justice of the Peace, who read its contents to him and confirmed his understanding. The record did not substantiate the claim of a promise of leniency. Critically, the Court noted that any promise made by military investigators, who are not prosecuting officers with the authority to fulfill such promises, does not render a confession inadmissible. The appellant, a resourceful individual who joined the Huks, was not so immature as to be easily duped. Furthermore, the confession was substantially corroborated by evidence of the corpus delicti. Testimony established that the victim was shot on the specified date and location while walking on a trail, sustaining multiple gunshot wounds. The existence of a jealous motive was supported by the testimony of the victim’s mother. Minor discrepancies, such as the exact hour of the shooting or whether the victim was the actual suitor of Gervacia, were deemed immaterial, as the appellant’s belief in the rivalry was what motivated the act. The Court found the killing attended by treachery, qualifying it as murder, but found insufficient evidence for evident premeditation. The penalty of reclusion perpetua and an indemnity were thus affirmed.