G.R. No. L-20038; July 28, 1966
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DELFIN ABRERA and ROMY UBANA, defendants. DELFIN ABRERA, defendant-appellant.

FACTS

Delfin Abrera and Romy Ubana were accused of murder in the Justice of the Peace Court of Labo, Camarines Norte, for the killing of Demetrio Copino, Jr. Both initially pleaded guilty. The case was elevated to the Court of First Instance where an information for murder was filed. Upon re-arraignment, Ubana pleaded guilty (and, being a minor, was sentenced to an indeterminate penalty) while Abrera pleaded not guilty. After trial, Abrera was found guilty and sentenced to death. The prosecution evidence showed that after Copino was reported missing, the Chief of Police investigated and found a decomposed body in a grave. The accused were taken for investigation. They initially denied knowledge but later admitted to the killing. Their separate sworn statements detailed that due to Copino’s domineering character, Ubana planned the killing. One night in November 1961, while Copino was sleeping, Ubana hit his head with a piece of wood, after which Abrera also hit him with the same wood. They then carried and buried the body in a pre-dug grave. A skull recovered from that grave was identified by the victim’s mother. At trial, Ubana testified to exculpate Abrera, claiming he alone killed Copino and that he implicated Abrera because his mind was unclear and later threatened Abrera to confess. Abrera claimed his confession was coerced by fear of Ubana.

ISSUE

Whether the extrajudicial confession of Delfin Abrera, corroborated by the evidence presented, is sufficient to sustain his conviction for murder.

RULING

Yes. The Supreme Court affirmed Abrera’s conviction but modified the penalty from death to reclusion perpetua. The Court held that Abrera’s extrajudicial confession was admissible and sufficiently corroborated by evidence of the corpus delicti. The rule requiring corroboration does not mean all elements of the crime must be established by independent evidence, only that there be some evidence tending to show the commission of the crime apart from the confession. Here, the corpus delicti was established by the discovery of a skull and decomposed human body in the grave pointed to by Ubana, which was identified as that of the victim. The detailed confessions of both accused, which included demonstrations of how the crime was committed, were consistent with this physical evidence. The Court found Abrera’s claim that his confession was coerced by fear of the younger and smaller Ubana not credible. Furthermore, Abrera had initially pleaded guilty before the Justice of the Peace Court. However, due to a lack of unanimity solely on the imposition of the death penalty, the sentence was reduced to reclusion perpetua. The decision was affirmed in all other respects.