G.R. No. L-30307 August 15, 1974
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JORGE FELICIANO Y GARCIA AND ABRAHAM GARCIA Y PURIFICACION, defendants-appellants.

FACTS

The accused, Jorge Feliciano and Abraham Garcia, were charged with Robbery with Homicide. The information alleged that on February 8, 1967, in Manila, they conspired with others to rob Alberto Ila of his passenger jeepney. On the occasion of the robbery, and to facilitate the taking of the vehicle, they attacked and killed Ila. The victim, a jeepney driver, went missing on that date. His body was later discovered in San Miguel, Bulacan, inside a burlap sack, with his hands and feet bound, and bearing a gunshot wound and injuries from a blunt instrument. His jeepney was never recovered. During the investigation, both accused gave extrajudicial confessions to police investigators, detailing how they lured the victim from Manila to Bulacan under a pretext, robbed him, and then killed him. The trial court found them guilty beyond reasonable doubt and imposed the death penalty, appreciating several aggravating circumstances.

ISSUE

The core issues for review were: (1) the admissibility and sufficiency of the accused’s extrajudicial confessions to establish guilt; (2) the lack of established motive and eyewitnesses; and (3) the jurisdiction of the Manila court over the crime.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua due to the lack of the required votes for death. The Court held the extrajudicial confessions admissible. While unsigned, the oral testimonies of the investigators regarding the substance of the admissions were permissible, as the confessions were made prior to the 1973 Constitution and in Tagalog, a dialect fully comprehended by the accused. The confessions were detailed and corroborated by the physical evidence and the circumstances of the victim’s disappearance and discovery. The lack of a proven motive and the absence of eyewitnesses were deemed inconsequential, as the evidence, particularly the confessions, left no reasonable doubt as to the accused’s culpability. On jurisdiction, the Court ruled that Manila courts properly exercised jurisdiction because an essential ingredient of the crime—the act of luring the victim and the inception of the conspiracy—occurred in Manila, pursuant to Section 14(a) of Rule 110 of the Revised Rules of Court. The crime commenced in Manila when the victim was deceived into going with the accused, thus vesting jurisdiction in the Manila court.