G.R. No. L-20806-07 August 14, 1965
People of the Philippines, plaintiff-appellee, vs. Alejandro Dayday alias Ando, Damiano Barton alias Damin and Santos Sinodlao alias Man Aninga, defendants-appellants.

FACTS

The spouses Simplicio Litan and Crispina Likayan were found brutally slain in their farmhouse in Camarahan, Talakag, Bukidnon, on May 18, 1960. Their two young daughters, Nilda (4) and Yolanda (2), were missing. Investigation by the Philippine Constabulary led to the apprehension of appellants Alejandro Dayday, Damiano Barton (Damin), and Santos Sinodlao (Man Aninga). Each executed separate sworn confessions before the municipal mayor and justice of the peace, detailing their conspiracy. The plan, conceived on May 15, 1960, at Manlikisa’s house in Napayag, was to kill the Litan couple and kidnap their two children for sale to Moros. Dayday agreed, partly to avenge his brother, who was previously killed by a relative of Crispina. On the night of May 16, 1960, the three attacked the sleeping couple with bolos, killing them. They then took the children. While fleeing, Dayday, noticing Nilda was severely wounded, stabbed and killed her. Yolanda was taken to La Roxas and hidden. The confessions were corroborated by physical evidence: a flashlight cap found at the crime scene matched Man Aninga’s flashlight; the murder weapons (bolos) were recovered; Nilda’s body was found based on Damin’s sketch; and Yolanda was rescued based on Man Aninga’s information. At trial, the appellants repudiated their confessions, claiming they were forced to sign, and presented alibis.

ISSUE

The primary issue is whether the sworn extrajudicial confessions of the appellants, subsequently repudiated at trial, are admissible and sufficient to prove their guilt beyond reasonable doubt for the complex crime of kidnapping with murder and the separate crime of murder.

RULING

The Supreme Court affirmed the trial court’s judgment, finding the appellants guilty beyond reasonable doubt. The Court ruled that the extrajudicial confessions were voluntarily given and admissible. The confessions were sworn to before the municipal mayor and the justice of the peace, who testified that the statements were translated into the Binukid dialect, explained to the appellants, and affirmed by them as true and voluntary. The appellants’ bare denial of knowledge of the contents could not prevail over this disinterested official testimony. The confessions were detailed, interlocking, and contained facts unknown to the investigators, which led to the discovery of corroborative evidence (the body, the child, the weapons, and the flashlight), demonstrating their reliability. The defense of alibi was weak and could not overcome the positive evidence of guilt. The Court also rejected the argument for leniency based on the appellants’ alleged backwardness, stating that the law must be enforced uniformly across the country. The penalty of death for the complex crime of kidnapping with murder was imposed as mandated by law.