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 standing guard, proceeded to the hut. Despite Reyes’s plea not to shoot as his young son was inside, Padilla and Macaso fired two volleys into the hut, killing Cenon Albea and his two sons. The accused then ordered the witnesses to throw the bodies into a creek. The three accused later made oral confessions before the chief of police in the presence of Cenon Albea’s corpse. At trial, Padilla and Vicente denied involvement, presenting alibi and denial defenses.

ISSUE

1. Whether the oral extrajudicial confessions of the accused are admissible as evidence.
2. Whether the testimony of a single witness (the chief of police) regarding the confessions, without corroboration, is sufficient for conviction.
3. Whether accused Benedicto Vicente should be held as a principal or merely an accomplice.
4. Whether the accused should be convicted of one complex crime or three separate murders.

RULING

1. Yes. There is no legal provision in the jurisdiction prohibiting the admission of an oral confession. A confession need not be in writing and may be proved by witnesses who heard it, as supported by Philippine and American jurisprudence.
2. Yes. The lack of corroboration affects only the witness’s credibility, not the admissibility of his testimony. If the testimony satisfies the court of the accused’s guilt beyond reasonable doubt, it is sufficient. Here, the confessions corroborate the eyewitness account and the physical evidence of the bullet-riddled corpses.
3. Benedicto Vicente is a principal by direct participation. His concerted actions—helping to corner the witnesses, ordering the retrieval of the shotgun and dog, and standing guard during the shooting—reveal a common purpose in the execution of the crime, making him a co-principal, not a mere accomplice.
4. The accused are guilty of three separate murders. The evidence shows several shots were fired in two rapid successions. Since the victims were not killed by a single act, the accused committed three distinct crimes under Article 48 of the Revised Penal Code.

DISPOSITIVE:
The appealed decision is modified. Appellants Francisco Padilla and Benedicto Vicente, together with Pedro Macaso, are each sentenced to suffer three penalties of reclusion perpetua. However, pursuant to Article 70 of the Revised Penal Code, their total imprisonment shall not exceed forty years. The indemnity and costs imposed by the lower court are affirmed.

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