G.R. No. L-58170 June 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERNESTO FLORES, accused-appellant.

FACTS

The accused-appellant, Ernesto Flores, was charged with the rape with homicide of thirteen-year-old Jesusa Maning on October 4, 1972. The prosecution established that the victim was last seen walking near a cornfield with Flores. Her body was discovered later that night in the said cornfield. The post-mortem examination by Dr. Victor Castronueva confirmed the victim died of asphyxia, had recent hymenal lacerations, and her mouth was filled with soil. The prosecution’s case heavily relied on two extrajudicial confessions allegedly executed by Flores before Municipal Judge Reyno and PC Investigator Sgt. Concepcion, wherein he admitted to raping the victim and stuffing her mouth with soil.
The defense contended that these confessions were inadmissible, being products of coercion. Flores testified that he was severely beaten by soldiers to extract the first confession and was not informed of his constitutional rights. He claimed the second confession was merely a reiteration of the first under duress. He presented witnesses, including a medico-legal officer, who testified to injuries on his body consistent with his claim of maltreatment.

ISSUE

The core issue is whether the extrajudicial confessions of the accused are admissible as evidence against him, having been voluntarily given and with proper safeguards observed.

RULING

The Supreme Court affirmed the conviction, ruling the confessions were admissible and constituted proof of guilt beyond reasonable doubt. The legal logic centered on the presumption of regularity in the performance of official duty by Judge Reyno and the investigating officer. The Court found no compelling evidence to overturn this presumption, as the defense failed to prove the alleged violence and irregularities with clear and convincing evidence. The detailed nature of the confessions, which aligned with the medico-legal findings, indicated they were given freely and intelligently.
Furthermore, the Court applied the rule that an extrajudicial confession, if corroborated by evidence of the corpus delicti—the fact of the rape and the homicide—is sufficient for conviction. The medical evidence and testimonies of witnesses who found the victim’s body provided the necessary corroboration. The defense of alibi was rightly rejected for being weak and unsubstantiated. The totality of the admissible confession and the corroborative evidence established the guilt of the accused-appellant beyond moral certainty.