G.R. Nos. L-15201 and L-15202; October 31, 1962
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. POLICARPIO TIONGSON Y GARCIA and MAURICIO NAVARRO Y ORDILLO, defendants-appellants.

FACTS

The case involves the compulsory review of death sentences imposed on Policarpio Tiongson and Mauricio Navarro for the crime of Robbery with Homicide. The victim, William Co Chi Chay, was found brutally murdered inside his Champion Watch and Jewelry Store in Manila on October 19, 1958, having died from skull fractures caused by a blunt object like a monkey wrench. The store was ransacked, with numerous watches stolen. Investigations led to the arrests of Tiongson, Navarro, and accomplices Rufino Galang and Salvador Villaveles. Tiongson and Navarro each executed sworn extrajudicial confessions admitting to the robbery but each blaming the other for the actual killing. The trial court found that the defendants, needing money, conspired to rob the store. Tiongson, acquainted with the victim, gained entry under the pretext of returning a repaired watch and then struck the deceased. Meanwhile, Navarro gathered the stolen watches. Their getaway was facilitated by Villaveles, who drove the car.
On appeal, both appellants challenged the validity of their confessions, claiming they were extracted through force and intimidation. Tiongson also assailed the trial court’s reliance on the uncorroborated testimony of co-conspirator Salvador Villaveles and presented an alibi, claiming he was in Novaliches watching basketball games at the time of the crime. Navarro similarly raised an alibi and argued that the prosecution failed to prove conspiracy with evidence independent of the confessions. Tiongson further filed a motion for new trial based on a recanting affidavit from Villaveles.

ISSUE

The core issues are: (1) the voluntariness and admissibility of the appellants’ extrajudicial confessions; (2) the sufficiency of the evidence, particularly the testimony of an accomplice, to establish conspiracy and guilt beyond reasonable doubt; and (3) the validity of the appellants’ alibi defenses.

RULING

The Supreme Court affirmed the convictions and death sentences. On the first issue, the Court found the confessions to be voluntary and admissible. Navarro signed his statement before a fiscal who explained its contents, and he was allowed to make corrections; a subsequent physical examination revealed no signs of maltreatment. Galang’s confession was also translated and explained to him. Tiongson’s claim of coercion was supported only by his own testimony and was contradicted by evidence suggesting his injuries were inflicted by the victim’s brother, not the police. The Court noted the confessions contained intricate details unlikely to be police inventions and the mutual accusations between the appellants, which indicated their statements were freely given.
Regarding the evidence of conspiracy and guilt, the Court held the testimony of accomplice Salvador Villaveles was credible and sufficiently corroborated the confessions and the physical evidence. While such testimony requires caution, no part of it was shown to be false. The conspiracy was clearly established by Villaveles’s account of the planning and execution of the crime. The appellants’ alibis were thoroughly discredited. Tiongson’s alibi was contradicted by his own co-accused’s statement placing him at the scene. Navarro’s alibi was deemed fabricated due to inconsistencies in his and his witnesses’ testimonies about his whereabouts and his own admission in his sworn statement of being in Manila on the crime date. Finally, the motion for new trial based on Villaveles’s recantation was denied, as recantations by convicts are notoriously unreliable and untrustworthy. The judgment of the trial court was affirmed in all respects.