GR L 4218; (May, 1952) (Digest)
G.R. No. L-4218-19 May 19, 1952
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GENARO OBENIA, ROBERTA RASALAN, and ANSELMO HUGO, defendants-appellants; THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO ABRIS, defendant-appellant.
FACTS
On January 19, 1948, Emilio Andaya was arrested by men under Huk leader Anselmo Hugo. That evening, he was brought to barrio Alitao and killed under Hugo’s orders, then buried in a grave dug by Anastacio Valdez and Jesus de la Cruz. Andaya was the husband of defendant Roberta Rasalan. The Constabulary investigated the crime, and the defendants were later apprehended. Anastacio Valdez disclosed the burial location, leading to the exhumation of Andaya’s remains. Valdez implicated all defendants in an affidavit. Roberta Rasalan and Domingo Abris signed confessions stating they agreed to hire Abris to kill Andaya, but Abris instead delivered Andaya to Hugo. Hugo and Obenia pleaded the defense of amnesty, claiming Andaya was an MP spy whose execution was ordered by their superior, Colonel Absalon. The trial court convicted the defendants, finding them guilty based on Valdez’s testimony, the confessions, and pleas of guilty entered during the preliminary investigation.
ISSUE
1. Is the evidence submitted sufficient to justify appellants’ conviction?
2. Are the appellants Hugo and Obenia entitled to the benefits of Amnesty Proclamation No. 76?
RULING
1. The evidence is insufficient to sustain the convictions. The testimony of the principal witness, Anastacio Valdez, was found illogical, improbable, and untrustworthy. His account of the killing was unnatural, and his statements were inconsistent and prone to change. The confessions of Roberta Rasalan and Domingo Abris were deemed inadmissible as they were secured through force and violence. Their pleas of guilty in the justice of the peace court were also tainted by the same threats. Without corroborating evidence, the testimony of Valdez, an accomplice, is insufficient to convict Rasalan and Abris. Therefore, Roberta Rasalan and Domingo Abris are acquitted on the ground that their guilt has not been proved beyond reasonable doubt.
2. Appellants Anselmo Hugo and Genaro Obenia are entitled to the benefits of Amnesty Proclamation No. 76. The evidence established that the deceased, Emilio Andaya, was a spy for the MPs who had caused the arrest of Huks. His execution by order of the Huk command was an act incident to or in furtherance of the crimes of rebellion or sedition, which is covered by the amnesty. Their timely applications for amnesty, filed while under detention, entitle them to its benefits. Consequently, Hugo and Obenia are absolved from all responsibility pursuant to the amnesty proclamation. The judgment of the trial court is reversed.