GR L 32866; (September, 1984) (Digest)
G.R. Nos. L-32866-7 September 21, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFONSO SABILANO Y FIRMANES, defendant-appellant.
FACTS
The accused, Alfonso Sabilano, was convicted by the Circuit Criminal Court of Manila for two counts of murder and sentenced to death for the shooting deaths of Eduardo Dasmariñas and Benilda Macalde. The victims, officers of an activist organization, were shot while waiting for transportation after a meeting. The prosecution’s case rested primarily on Sabilano’s extrajudicial confession, where he admitted being present at the scene and named Ruben Guevarra as the gunman. The defense challenged the confession’s admissibility, claiming it was extracted through intimidation and violence during police interrogation without the assistance of counsel.
ISSUE
The core issue is whether the extrajudicial confession, being the sole basis for conviction, is admissible and sufficient to prove the accused’s guilt as a co-conspirator in the murders beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted the accused. The Court held that the extrajudicial confession was inadmissible. It was obtained during a custodial investigation where the accused was not informed of his right to remain silent and to counsel, rendering the confession involuntary and in violation of constitutional rights. Even assuming the confession was admissible, it was insufficient to sustain a conviction. The confession itself did not establish conspiracy; it merely placed the accused at the crime scene and identified another individual as the shooter. For conspiracy to exist, there must be clear and convincing evidence of a common criminal design. The testimony of prosecution witnesses corroborated that the assailant was a man in a white polo shirt, not the accused, and merely seeing the accused fleeing the scene is not proof of conspiracy. In the absence of any competent evidence, direct or circumstantial, linking the accused to a conspiracy to kill the victims, his mere presence at the scene does not constitute criminal liability. The prosecution failed to prove his guilt beyond reasonable doubt.