G.R. No. L-2866; April 26, 1950
EL PUEBLO DE FILIPINAS, plaintiff-appellee, vs. PEDRO MACASO, ET AL., defendants. BENEDICTO VICENTE and FRANCISCO PADILLA, appellants.

FACTS

On the evening of June 22, 1948, in Boñgabon, Nueva Ecija, accused Francisco Padilla, Pedro Macaso, and Benedicto Vicente disarmed witnesses Juan Reyes and Geronimo Domingo. They then ordered Geronimo to retrieve a dog and a shotgun from a nearby hut where Cenon Albea and his two sons, Reynaldo and Edilberto, were sleeping. The accused, with Vicente acting as a lookout, proceeded to the hut. Despite Reyes’s pleas (as his young son was also inside), Padilla and Macaso fired two volleys of shots into the mosquito net where the Albeas slept, killing all three. The victims’ bodies were found with multiple gunshot wounds. The accused were later brought before the corpse of Cenon Albea in the municipal hall, where each orally confessed to their participation in the killings to the police captain. At trial, the accused denied the confessions and their involvement, presenting alibis and claiming the police testimony was uncorroborated.

ISSUE

1. Whether the oral extrajudicial confessions of the accused are admissible as evidence.
2. Whether the trial court erred in convicting the accused based on the uncorroborated testimony of the police captain regarding the confessions.
3. Whether accused Benedicto Vicente should be liable as a principal or merely as an accomplice.
4. Whether the accused should be convicted of one complex crime or three separate murders.

RULING

1. Yes, the oral confessions are admissible. Philippine law does not require confessions to be in writing. Oral confessions are admissible and may be proved by witnesses who heard them, as supported by jurisprudence and American authorities.
2. No, the trial court did not err. The lack of corroboration affects only the credibility of the witness. The testimony of the police captain, if believed by the court to establish guilt beyond reasonable doubt, is sufficient. The court found his testimony credible, and the confessions were corroborated by the testimony of eyewitness Juan Reyes and the physical evidence of the bullet-riddled corpses.
3. Benedicto Vicente is liable as a principal, not an accomplice. The concerted actions of all three accused—disarming the witnesses, securing the area, retrieving the weapon, and Vicente acting as a lookout while the others fired—reveal a common criminal purpose, making each a co-principal.
4. The accused are guilty of three separate murders, not one complex crime. The evidence shows multiple shots were fired in two rapid successions, indicating a clear intent to kill each victim. Therefore, they are liable for three distinct crimes under Article 48 of the Revised Penal Code.

The Supreme Court modified the trial court’s judgment. Appellants Francisco Padilla and Benedicto Vicente, together with Pedro Macaso, are each sentenced to suffer three penalties of reclusion perpetua. However, applying Article 70 of the Revised Penal Code, their total imprisonment shall not exceed 40 years. The awards of indemnity and costs are affirmed.

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