G.R. No. L-30060 July 30, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. DEMETRIO ROBLES, SANTIAGO BINGCO and DIONESIO ALABE, defendants, SANTIAGO BINGCO, defendant-appellant.

FACTS

On the night of August 29, 1966, the house of spouses Exequiel Manigos and Remedios Gutang in Bansalan, Davao, was robbed. Exequiel was shot and later died, and cash and personal belongings worth P520.00 were taken. The incident was reported the next day. The widow, Remedios, initially informed police she could identify one of the four robbers—the man standing by the door. On September 5, 1966, she was brought to a police line-up where she identified Santiago Bingco, who was already in detention for a separate trespassing case. Bingco later executed a sworn extrajudicial confession on September 9, admitting participation and naming his companions. Based on this confession and Remedios’s identification, an information for robbery in band with homicide was filed.
At trial, the prosecution’s case rested primarily on the testimony of Remedios Gutang and Bingco’s extrajudicial confession. Remedios testified that during the robbery, one robber stood by the door, illuminated by a nearby bottle lamp, whom she identified as Bingco. She detailed his actions, including ordering her husband to lie down and tying his feet. The defense, however, presented a different narrative. Bingco repudiated his confession, claiming it was extracted through maltreatment and a false promise of being made a state witness. He also interposed the defense of alibi, asserting he was elsewhere at the time of the crime.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Santiago Bingco for the crime of robbery in band with homicide beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED Santiago Bingco. The Court found the evidence insufficient to establish his guilt beyond a reasonable doubt. The legal logic centered on the unreliability of the sole eyewitness identification and the inadmissibility of the extrajudicial confession. Regarding the identification by Remedios Gutang, the Court noted serious inconsistencies. Her testimony in court—that Bingco was the man by the door who shot her husband—contradicted her initial statement to police where she only identified the man by the door and did not mention him as the shooter. This major discrepancy cast doubt on the reliability of her in-court identification, which is crucial when it is the primary evidence linking the accused to the crime.
Furthermore, the Court ruled the extrajudicial confession was inadmissible. Bingco’s claim of police maltreatment and inducement was not convincingly rebutted by the prosecution. The confession was taken while he was already a detention prisoner, and the prosecution failed to prove it was given voluntarily, intelligently, and knowingly. Without this proof, the confession had no probative value. The Court emphasized that an extrajudicial confession, especially one repudiated, must be corroborated by evidence of corpus delicti to be credible. Here, the other evidence was weak and did not independently corroborate the confession. Consequently, with the eyewitness identification deemed unreliable and the confession invalidated, the prosecution failed to meet the high standard of proof required for a criminal conviction. The presumption of innocence prevailed.