G.R. No. L-2448

FACTS:
The defendants-appellants, Sixto Mercado et al., were charged with a crime. The prosecution’s primary evidence consisted of written confessions signed and sworn to by each appellant before the justice of the peace of Mabalacat. At the trial in the Court of First Instance, the appellants denied the truth of these confessions, alleging they were the result of violence, intimidation, and threats by Constabulary officers prior to being brought before the justice of the peace. The justice of the peace testified that no improper measures were used in his presence, but he did not take steps to ascertain whether the appellants’ minds were free from fear induced by prior alleged abuse.

ISSUE:
Whether the alleged confessions of the appellants are admissible as evidence against them.

RULING:
No. The confessions are inadmissible. Under Section 4 of Act No. 619 , a confession is only admissible if it affirmatively appears to have been “freely and voluntarily made and not the result of violence, intimidation, threats, menace, or promises or offers of reward or leniency.” The Court held that where violence or intimidation is alleged to have been used to extract a confession, the mere fact that the confession later appears voluntary before an official is insufficient for its admission. It must be proven beyond a reasonable doubt that the accused’s mind was wholly relieved of the fear arising from such prior mistreatment. The prosecution’s evidence failed to meet this burden and was insufficient to rebut the appellants’ testimony. Consequently, with no other competent evidence connecting the appellants to the crime, they are acquitted. The complaint against appellants who died pending appeal is dismissed.