G.R. No. L-12687; July 31, 1962
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMITERIO VILLANUEVA, PEDRO PERCAL and FELIX JASMILONA, defendants-appellants.

FACTS

The defendants were charged with the murder of Loreto Estacio in Calamba, Laguna. The prosecution’s case relied heavily on the extra-judicial confession of appellant Felix Jasmilona, corroborated by circumstantial evidence. Jasmilona’s confession detailed that the killing occurred in the “taklab” (camarin) of co-accused Emiterio Villanueva, who resented a criminal complaint filed against him by the victim. The confession implicated Villanueva, his son, Pedro Percal, Elpidio Habacon, and Jasmilona himself, stating Percal delivered the fatal stab after the victim was beaten unconscious. The body was disposed of in a marshy area.
The trial court identified a chain of corroborating circumstances: Villanueva assaulted Estacio on December 21, 1955, leading to a criminal complaint. Villanueva attempted to have the complaint dropped and made threats. On the morning of December 27, witnesses saw the victim walking with Villanueva and Percal. Later that day, Percal and Jasmilona were seen heading toward Villanueva’s taklab, where sounds of groans and voices were heard that evening. The victim disappeared, and his body was found days later. Human blood was found in the taklab, and Villanueva’s wife acted suspiciously regarding a bloodstained pestle.

ISSUE

Whether the evidence, particularly Jasmilona’s extra-judicial confession and the circumstantial evidence, proves the guilt of all appellants beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The Court upheld the admissibility and credibility of Jasmilona’s confession. Jasmilona claimed it was extracted through torture, but the Court found the evidence of coercion unconvincing, noting a prosecution doctor found no injuries on him. Furthermore, the confession was admissible against his co-accused because they adopted his testimony and prior statement as part of their defense, making it competent evidence to contradict them under the exception to the hearsay rule established in People vs. Manalo.
The Court found the circumstantial evidence compelling and consistent with the confession. The sequence of events—the motive, threats, sightings of the appellants with the victim near the crime scene, the sounds from the taklab, the discovery of blood, the suspicious conduct of Villanueva’s wife, and the recovery of the body—formed an unbroken chain leading to the reasonable conclusion that all appellants participated in the crime. This evidence sufficiently established conspiracy among them, demonstrating common purpose and concerted action. The trial court’s judgment was upheld, with the penalty corrected to reclusion perpetua.