G.R. No. L-37482 July 25, 1984
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS R. MATERNAL, EMILIO G. AMAR, JR., ZOSIMO IGAO and NORBERTO RELOJAS, accused, CARLOS R. MATERNAL, accused-appellant.

FACTS

On August 27, 1969, Juan Cabasal went to Panamonton Beach in Palawan to sleep in his boat, bringing personal belongings including a “Fujiya” radio-phono. The following day, he was found dead in the sea, having sustained eleven wounds. During the investigation, police acting on leads went to Barrio Tagpirara, where they found the victim’s radio in the possession of appellant Carlos Maternal, an escapee from the Iwahig Penal Colony. Maternal was arrested and subsequently gave an extrajudicial confession (Exhibit “C”) before Municipal Judge Nicolas Feliciano, detailing his and his companions’ involvement in the robbery and killing of Cabasal. At trial, Maternal repudiated this confession, claiming he signed it under duress—that he was kicked and threatened by police. He testified that while he was present during the incident, it was his companions who actually killed the victim after they failed to start the boat’s engine, and that he even admonished them to stop.

ISSUE

The core issues are: (1) the admissibility and voluntariness of Maternal’s extrajudicial confession; (2) the sufficiency of that confession to sustain a conviction for robbery with homicide; and (3) the propriety of imposing the death penalty.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The extrajudicial confession was deemed admissible and voluntarily given. The legal logic rests on the presumption that a confession is voluntary unless convincingly rebutted. Maternal’s claim of coercion was uncorroborated; he filed no administrative or criminal complaints against the alleged perpetrators. The confession’s reliability is bolstered by the judicial safeguards observed—it was read to him, he affirmed its contents, and he swore to its truth before a municipal judge. Furthermore, the Court found it significant that his two co-accused, who were similarly in custody, were not forced to give any confession, indicating an absence of systematic coercion. Maternal’s own testimony did not deny his presence at the crime scene, only his direct participation. A confession, if voluntary, is evidence of a high order, as a person of normal mind would not knowingly confess to a crime unless prompted by truth. The trial court correctly convicted him of robbery with homicide based on this confession and the corroborative evidence of the recovered radio. Regarding the penalty, the trial court imposed death due to quasi-recidivism under Article 160 of the Revised Penal Code, as Maternal committed the crime while serving a sentence. However, for lack of the necessary votes, the Supreme Court reduced the penalty to reclusion perpetua. The Court also ordered an indemnity of P30,000.00 to the victim’s heirs.