G.R. No. L-17215, L-17216, L-17217 February 28, 1967.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CATALINO SANTOS alias LINO, TABBEGAT BOCTO, PABLO BASILIO, and SINGGUP OLMEHEMET, defendants-appellants.

FACTS

Three interrelated cases were jointly tried. In Criminal Cases No. 798 and 800, appellants Catalino Santos and Tabbegat Bocto were convicted of illegal possession of firearms and ammunition. In Criminal Case No. 802, appellants Santos, Bocto, Pablo Basilio, and Singgup Olmehemet were convicted of three murders. The victims, Flaviano Fontanilla and his sons Raymundo and Victorino, were ambushed on March 12, 1958, while walking on a trail along Sagat Creek. They were shot by individuals hiding in foxholes, after which the assailants emerged, beheaded and hacked the bodies. An eyewitness, Artemio Simanero, who was with the victims but hid, later identified the appellants and state witness Obdiy-ya Antolin as the perpetrators. The appellants were rounded up, and Simanero identified them. During a preliminary hearing, they pleaded guilty to the charges. The prosecution presented evidence including eyewitness testimonies (Simanero and Antolin), confessions subscribed before the justice of the peace, recovery of personal belongings from the foxholes, and recovery of unlicensed firearms (Japanese rifles) used in the crime. Appellants denied the charges and claimed their confessions were obtained through duress.

ISSUE

The main issue is one of fact: whether the appellants were responsible for the killings of the Fontanillas and the illegal possession of firearms.

RULING

The Supreme Court affirmed the convictions but modified the penalty for Catalino Santos in the murder case. The Court found the testimonies of eyewitnesses Simanero and Antolin credible and corroborated by the appellants’ confessions, the recovery of personal effects from the foxholes, and the recovery of the firearms. The Court rejected the claim that the confessions were obtained through duress, noting the confessions were detailed, subscribed before a justice of the peace, and the signatures appeared firm. Regarding the murder convictions, the Court found the killings qualified by treachery and aggravated by evident premeditation, commission in an inhabited place, use of unlicensed firearms, and by a band. However, for Catalino Santos, the Court reduced his penalty from death to three life imprisonments, considering his limited schooling, his environment as a leader of the Ilongot community, and his motive (to defend land claimed by the Ilongots against what he perceived as oppression by the former mayor, Flaviano Fontanilla). The penalties for the other appellants were affirmed. The decision of the lower court was affirmed in all other respects.