G.R. No. L-33607 December 14, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO MADLANGBAYAN Y BONET, defendant-appellant.

FACTS

Antonio Madlangbayan was charged with robbery with homicide for the December 27, 1970, killing of Enrique Fallarme in Manila. The prosecution established that the victim, a supervising engineer, was stabbed to death at a construction site. His son, Elywelyn, later found the body and discovered that his father’s wallet containing P300 and a Seiko wristwatch were missing. The police, acting on an informer’s tip, arrested Madlangbayan. During the wake, he was brought to view the cadaver and identified the deceased as the man he had stabbed. He subsequently gave a detailed extrajudicial confession, written in Tagalog and sworn to before a fiscal, wherein he admitted participating in the robbery with three companions, stabbing the victim when he moved his hands. The confession was corroborated by a crime re-enactment.
At trial, Madlangbayan repudiated his confession, claiming it was coerced through physical abuse by the arresting officers. He presented an alibi, testifying that he was at his uncle’s birthday celebration in Pandacan, approximately 500-600 meters from the crime scene, during the time of the incident. The trial court rejected the defense, found the confession voluntary and credible, and convicted him, imposing the death penalty due to the aggravating circumstance of abuse of superior strength.

ISSUE

The core issue is whether the accused-appellant’s conviction for robbery with homicide, based primarily on his extrajudicial confession, is valid despite his claims of coercion and alibi.

RULING

The Supreme Court affirmed the conviction. The legal logic centered on the admissibility and corroboration of the extrajudicial confession. The Court held that the confession was voluntarily given. The appellant affirmed its contents before the inquest fiscal without complaint, and his claim of coercion was uncorroborated and belied by his participation in the detailed re-enactment. Critically, the Court found the confession amply corroborated by evidence of the corpus delicti—the fact that a crime was committed. Independent evidence, including the son’s testimony, the medical examiner’s report on the fatal stab wounds, and the proof of the stolen items, sufficiently established that a robbery with homicide had occurred, wholly apart from the confession itself.
This independent proof of the corpus delicti satisfied the legal requirement that a confession must be corroborated by evidence outside of itself. The appellant’s alibi was rightly dismissed by the trial court; the proximity of his alleged location to the crime scene did not make his presence there impossible, and the testimony of his uncle regarding his arrival time was inconclusive. The aggravating circumstance of abuse of superior strength was correctly appreciated, as the appellant and his three cohorts, two armed, surrounded and attacked the unarmed victim. Consequently, the judgment of conviction, including the penalty, was upheld.