G.R. No. L-32832 June 29, 1979
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUIS BERALDE, defendant-appellant.

FACTS

On the night of July 31, 1968, the bodies of spouses Constantino Bose and Consolacion Bose were found dead on a road in Bangued, Abra. Constantino was discovered with a plow yoke still on his shoulder, holding a rope tied to a grazing cow. Investigation by Chief of Police Narciso Laureta revealed that earlier that evening, Patrolman Eduardo Bringas had seen appellant Luis Beralde and Jaime Bringas near the crime scene. Beralde stated he was waiting for his wife. The following day, Jaime Bringas was apprehended and confessed that Beralde had revealed his plan to kill the couple; Jaime tried to dissuade him and left, after which Beralde later arrived at his home stating, “they were already dead.”
Beralde was then taken into custody. After initial evasion, he confessed to the killings, detailing how he attacked the victims with a bolo as they passed by. His extrajudicial confession was reduced to writing. The prosecution presented this confession, autopsy reports, the recovered bolo, and testimonies from investigating officers. No eyewitness to the actual killings was presented. The defense relied solely on alibi, claiming Beralde was elsewhere at the time.

ISSUE

The core issue is whether the extrajudicial confession of the appellant, corroborated by circumstantial evidence, is sufficient to sustain his conviction for double murder beyond reasonable doubt, despite the lack of an eyewitness.

RULING

Yes, the conviction is affirmed. The Supreme Court held that an extrajudicial confession, if voluntarily given and corroborated by evidence of corpus delicti, is a potent evidence of guilt. The Court found Beralde’s confession to be detailed, spontaneous, and given without coercion. It was corroborated by the physical evidence and the timeline established by Patrolman Bringas who placed Beralde near the crime scene shortly before the murders. The confession was also consistent with Jaime Bringas’s account of Beralde’s homicidal intent.
The defense of alibi was correctly rejected by the trial court as weak and unsubstantiated, especially in light of the strong evidence of guilt. The Court also upheld the finding of treachery (alevosia), qualifying the killings as murder, as the sudden and violent attack with a bolo ensured the victims had no opportunity to defend themselves. The penalty for each murder was properly imposed at reclusion perpetua. However, applying Article 70 of the Revised Penal Code on the service of multiple penalties, the Court modified the sentence to ensure that the total period of imprisonment shall not exceed forty years.