G.R. Nos. L-27677-8-9. January 22, 1988. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROGELIO TAGARA, alias EDUARDO TAGARA, defendants-appellants.
FACTS:

Eduardo Tagara and Rogelio Tagara were charged with Double Murder, Robbery, and Arson before the Court of First Instance of Tarlac. Eduardo pleaded guilty to murder and later to robbery. The trial proceeded against Rogelio for murder and robbery, and against both brothers for arson, with the cases tried jointly. The prosecution established that on May 19, 1965, the house of spouses Leonato Gabriel and Solita Yadao in Barrio Sierra, La Paz, Tarlac, was set ablaze. Their charred bodies were discovered inside. Investigation revealed the Tagara brothers had a prior misunderstanding with Leonato over a leased farm. Witnesses placed the brothers reconnoitering the victims’ house before the fire and fleeing the barrio immediately afterward.
The brothers were apprehended days later in another town. Rogelio was found carrying one of the victim’s rifles, and the diary of Solita Yadao was discovered in his pocket. Both appellants executed detailed, sworn extrajudicial confessions before a municipal judge, admitting to the crimes. They claimed they killed the spouses during a quarrel, robbed the house, and set it on fire to conceal the bodies.

ISSUE

The core issue is whether the extrajudicial confessions of the appellants, particularly Rogelio Tagara, are admissible and sufficient, alongside circumstantial evidence, to prove their guilt beyond reasonable doubt for the complex crimes charged.

RULING

The Supreme Court affirmed the conviction. The Court meticulously upheld the admissibility of the confessions, rejecting the appellants’ claim that they were extracted through force and intimidation. The legal logic centered on the established presumption of regularity in the performance of official duty by the officers who took the confessions. This presumption was not overcome by mere allegations. The confessions were found to be replete with interlocking details known only to the perpetrators, executed in an open municipal office with many people present, and sworn to before a municipal judge who observed no signs of coercion or injury on the appellants. A medical examination conducted a day later also revealed no physical evidence of maltreatment.
Furthermore, the Court ruled that the confessions were convincingly corroborated by strong circumstantial evidence of guilt. This included: (1) Rogelio’s possession of the victim’s rifle and the victim’s personal diary upon arrest; (2) the appellants’ flight from the barrio immediately after the crime; and (3) eyewitness accounts of their suspicious presence near the crime scene. These circumstances formed an unbroken chain leading to the fair and reasonable conclusion that the appellants were the perpetrators. The combination of the voluntary confessions and the corroborating physical and testimonial evidence established their guilt beyond a reasonable doubt for the crimes of murder, robbery, and arson.