G.R. No. L-55483 July 28, 1988
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAURICIO NOLASCO Y BONGAY, defendant-appellant.

FACTS

On July 21, 1979, sisters Carmelita Contapay-Bacay and Lilia Contapay-Laguitan, who were trash collectors, slept in their pushcarts outside their Tondo residence. Lilia, awake and tending to her children, witnessed two men approach. One man, later identified as Mauricio Nolasco, stabbed the sleeping Carmelita multiple times despite Lilia’s shouts. Carmelita died while being transported to the hospital. Lilia immediately identified Nolasco to the police. Nolasco was apprehended months later and, after a confrontation with Lilia, executed a sworn extrajudicial confession admitting to the stabbing. He was charged with murder.
At trial, the prosecution presented Lilia, who gave a positive in-court identification, and a medico-legal officer. Nolasco, as the sole defense witness, repudiated his confession, claiming it was extracted through police maltreatment. He offered no medical evidence of such harm and failed to report the alleged coercion to the administering fiscal. He also speculated that Lilia’s testimony was motivated by anger over local gang riots, suggesting she or the victim might have been hit by stones during such incidents.

ISSUE

The core issue is whether the trial court erred in convicting Nolasco of murder based on his extrajudicial confession and the eyewitness testimony, despite his claim that the confession was involuntary.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the validity of Nolasco’s extrajudicial confession. His claim of coercion was deemed unconvincing due to the lack of corroborating evidence, his failure to report the maltreatment to the fiscal when he had the opportunity, and the absence of marks of violence. The confession was detailed and contained facts known only to the perpetrator, indicating voluntariness. Furthermore, the confession was strongly corroborated by the credible and positive testimony of eyewitness Lilia, who had an unobstructed view of the crime under a well-lit area and identified Nolasco without delay. The Court found Nolasco’s proposed motive for Lilia’s testimony—anger over gang riots—to be speculative and insufficient to undermine her clear account. The crime was correctly classified as murder, qualified by treachery, as the attack was made on a sleeping and defenseless victim. Applying the Indeterminate Sentence Law and considering the abolition of the death penalty, the penalty was modified to an indeterminate sentence of ten years and one day of prision mayor, as minimum, to eighteen years, eight months and one day of reclusion temporal, as maximum. The civil indemnity was increased to P30,000.00.