GR L 25815; (May, 1969) (Digest)
G.R. No. L-25815 May 31, 1969
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON GOMEZ and RICARDO ALCANTARA, defendants-appellants.
FACTS
The defendants-appellants, Ramon Gomez and Ricardo Alcantara, were convicted of murder for the killing of Adelaida Roy Rubio inside her house in Meycauayan, Bulacan, on the evening of August 9, 1958. The prosecution’s primary eyewitness was the victim’s 13-year-old son, Buenaventura Rubio, who testified that two masked men entered their home and one shot his mother. He later identified Gomez and Alcantara in court, noting Gomez’s hairy arms. The prosecution also presented two sworn extra-judicial confessions (Exhibits “A” and “B”) executed by Alcantara, wherein he admitted his participation as a lookout while Gomez and another man, Felino Rubio, went upstairs to kill the victim. Alcantara later repudiated these confessions, claiming they were coerced through maltreatment and promises of exclusion from the case. Both appellants denied involvement and presented alibis.
ISSUE
The primary issue is whether the prosecution’s evidence, particularly the eyewitness identification and the extra-judicial confessions, is sufficient to prove the guilt of appellants Ramon Gomez and Ricardo Alcantara beyond reasonable doubt for the crime of murder.
RULING
The Supreme Court modified the trial court’s decision. It ACQUITTED Ramon Gomez because the eyewitness identification was insufficient and unreliable. The witness, Buenaventura Rubio, admitted he did not recognize the masked assailants on the night of the crime, and his subsequent identification of Gomez was flawed, as it was conducted under suggestive conditions (Gomez was shown masked but only among soldiers, not other civilians). The Court found no clear evidence linking Gomez to the murder.
However, the Court AFFIRMED the conviction of Ricardo Alcantara. It upheld the validity and admissibility of his extra-judicial confessions (Exhibits “A” and “B”), rejecting his claim of coercion as inconsistent and improbable. The confessions contained details unknown to investigators, and his failure to report the alleged maltreatment to the fiscal or clerk of court when he swore to the statements undermined his repudiation. Alcantara’s alibi was deemed weak. His confession, corroborated by the independent eyewitness testimony of Buenaventura Rubio and the necropsy report, established his guilt as a principal by conspiracy for acting as a guard during the murder. He was sentenced to reclusion perpetua (life imprisonment), ordered to indemnify the heirs of the victim in the sum of P12,000.00, and to pay one-half of the costs.