G.R. No. L-4258; May 15, 1953
People of the Philippines, plaintiff-appellee, vs. Dionisio Francisco, et al., defendants. Tiburcio Asuncion, Fedencio Fronda, Pedro Tabbal and Caritativo Dasalia, defendants-appellants.

FACTS

On the evening of January 3, 1948, Anacleto Fajardo disappeared. In August 1948, human remains identified as Fajardo’s were exhumed from a grave in the yard of Pablo Bugarin in Cordon, Isabela. Following this discovery, special agent Cornelio Feliciano questioned Mayor Dionisio Francisco, who allegedly confessed knowledge of the crime, implicating Lorenzo Saraus and others, and stating that Tiburcio Asuncion, Caritativo Dasalia, and Fedencio Fronda, who were at his house, went with Saraus to Bugarin’s yard where Fronda dug a grave and Asuncion did the killing. Asuncion, Fronda, and Pedro Tabbal were arrested and made signed written confessions to the Philippine Constabulary in Cordon, which they later repudiated at trial, claiming they were extracted through violence and intimidation. Subsequently, they made new sworn declarations before the Justice of the Peace of Santiago, as did Dasalia after his arrest. These confessions detailed that Mayor Francisco ordered them to kill a man brought by Saraus, and that Asuncion struck the victim with a bolo after which the body was buried. The trial court convicted Asuncion, Fronda, Tabbal, and Dasalia of murder based on these confessions, acquitting Francisco for lack of evidence.

ISSUE

The decisive question is the validity and admissibility of the appellants’ confessions, which they repudiated at trial on the grounds of violence and intimidation.

RULING

The Supreme Court affirmed the judgment of conviction. It held that the confessions were valid and admissible. The Court found the appellants’ claims of maltreatment not credible, noting the absence of physical signs of injury, the lack of motive for the officers to fabricate charges, and the fact that Dasalia was not subjected to any punishment. The confessions, taken by different officers at different times and places, were consistent in their essential features and contained details known only to the perpetrators. Corroborated by the discovery of Fajardo’s remains, they constituted sufficient evidence for conviction. The Court further found that the appellants were co-conspirators in a prearranged murder, as indicated by their presence and actions, making them equally liable for the crime.