GR L 35598; (May, 1987) (Digest)
G.R. No. L-35598. May 29, 1987.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO DE LOS SANTOS, accused-appellant.
FACTS
The accused-appellant, Leonardo de los Santos, was convicted of Murder by the Court of First Instance of Basilan City and sentenced to reclusion perpetua. The Information alleged that on November 29, 1971, in Tairan, Isabela, Basilan City, appellant and Alfredo Lacastesantos, conspiring and armed with a bolo and a knife, attacked and killed Gregorio Dotado with treachery and evident premeditation. Only appellant was arraigned and tried initially. The prosecution’s case relied heavily on appellant’s extrajudicial confession (Exhibit “D”), executed on December 7, 1971, wherein he admitted to hacking the victim due to a grudge over a woman and implicated Lacastesantos. The trial court convicted appellant based on this confession. Subsequently, the case against Lacastesantos was dismissed upon the prosecution’s motion, citing insufficient evidence apart from appellant’s implication.
ISSUE
The core issue is whether the extrajudicial confession of the appellant is admissible and sufficient to sustain his conviction for Murder.
RULING
The Supreme Court affirmed the conviction, holding the extrajudicial confession admissible and credible. The legal logic proceeds from the established principle that a confession constitutes evidence of a high order, as the presumption is that no sane person would confess to a crime unless prompted by truth. The Court found the confession to be replete with details only the perpetrator would know, indicating voluntariness. Crucially, the confession was obtained and the trial court’s decision rendered before the effectivity of the 1973 Constitution. Therefore, the constitutional safeguards requiring the informing of the right to remain silent and to counsel (Section 20, Article IV) were not applicable retroactively, as held in Magtoto vs. Manguera. The confession’s admissibility was governed by the rules of court then in force. Furthermore, the confession was corroborated by the corpus delicti—the fact of death established by the post-mortem examination—which satisfies the requirement for conviction under the rules of evidence. Appellant’s challenge regarding a minor discrepancy in the name of a house in the confession was deemed immaterial, especially since the affidavit containing the alternate name was never formally offered in evidence. The judgment was affirmed with the modification of increasing the indemnity to the heirs to P30,000.00.