G.R. No. L-36446, September 9, 1983
The People of the Philippines, Plaintiff-Appellee, v. Juan C. Maguddatu, Edipolo L. Maguddatu, Charles A. Maguddatu, Pedro Maguddatu and Antonio Cabayu, Accused.

FACTS

This is an automatic review of the death sentences imposed by the Court of First Instance of Cagayan for the double murder of brothers Rogelio and Cesario Ilac on January 25, 1972. The prosecution presented two conflicting narratives. The trial court relied on the testimony of Reynaldo Ilac, the victims’ brother and the sole alleged eyewitness. He claimed that seven armed men, including all five accused, accosted and mauled his brothers before taking them away. Their bodies were later found weighted down in a river.
The prosecution also offered the extrajudicial confessions of all five accused, who reiterated them in court. Their version differed significantly. They testified that while returning from a dance by motorized banca, they saw three men with a carabao and suspected them of cattle rustling. Upon landing, a pursuit ensued: Edipolo alone killed Cesario; Charles and Juan together killed Rogelio; Pedro and Cabayu chased the third man, who escaped. They then weighted and disposed of the bodies.

ISSUE

The core issue is which version of events establishes the criminal liability of the accused beyond reasonable doubt, and what are the proper crimes and penalties.

RULING

The Supreme Court held that the confessions of the accused, being admissions against penal interest, constitute the primary evidence and prevail over Reynaldo Ilac’s uncorroborated testimony. The Court noted material inconsistencies between Reynaldo’s trial testimony and his earlier sworn statement, where he omitted details of the assault, casting doubt on his credibility. The confessions reveal individual, not collective, responsibility for the killings. Edipolo was solely liable for killing Cesario, while Charles and Juan were jointly liable for killing Rogelio. Their claim of self-defense fails as the victims were unarmed. For these homicides, the Court found the aggravating circumstances of abuse of superiority, use of a motorized banca (in disposing of the corpses), and cruelty. Cruelty was present due to the outrage upon the corpses by weighting them with heavy objects. The mitigating circumstance of voluntary surrender was appreciated. Consequently, Charles and Juan Maguddatu were found guilty only of homicide, not murder, and were sentenced to an indeterminate penalty. Antonio Cabayu was acquitted as his guilt was not proven beyond reasonable doubt, as he only participated in the chase of the surviving brother. The death penalties were set aside.