G.R. No. L-36445 August 28, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NARCISO PIZARRO, defendant-appellant.

FACTS

In the evening of June 6, 1971, spouses Teodoro Taban and Maria Pescador were killed inside their home in Allacapan, Cagayan, sustaining gunshot wounds from a multiple-pellet firearm and stab wounds. Suspicion fell on their son-in-law, appellant Narciso Pizarro, due to his objection to burying the victims face downward—a local practice believed to prevent the killer from sleeping. Witnesses Filomeno de los Santos and Felipe Jose testified they saw Pizarro and a companion heading toward the victims’ house that evening, heard gunshots, and later saw two persons, one of whom was Pizarro, leaving the scene carrying a gun and a knife.
Appellant was apprehended and initially denied involvement. He later executed detailed extra-judicial confessions (Exhibits “C” and “E”) admitting to the double murder and revealing the location of the murder weapon, a bulldog gauge 16 gun, which was subsequently recovered. At trial, Pizarro recanted, claiming his confessions were extracted through police maltreatment and presenting an alibi that he was home at the time of the killings.

ISSUE

The core issue is whether the extra-judicial confessions of the appellant, allegedly obtained without the assistance of counsel and through coercion, are admissible as evidence to sustain his conviction for double murder.

RULING

The Supreme Court affirmed the conviction but reduced the penalty to double reclusion perpetua. The Court held the confessions admissible. The legal logic proceeds on two key points. First, even assuming the confessions were involuntary, they were corroborated by independently discovered facts, specifically the recovery of the murder weapon at the exact location Pizarro pinpointed. This corroboration on a material point validates the confessions under the doctrine that involuntary confessions confirmed by subsequent discoveries become admissible.
Second, the confessions were executed in July 1971, prior to the effectivity of the 1973 Constitution. The constitutional right to counsel during custodial investigation, as established in the 1973 Charter, was held to operate prospectively only. Therefore, a confession obtained before January 17, 1973, even without the accused being informed of his right to counsel, remained admissible as no such right was legally mandated at the time. The corroborated confessions, coupled with the eyewitness testimonies placing him at the scene, constituted proof of guilt beyond reasonable doubt.