G.R. No. L-9656; August 20, 1914
THE UNITED STATES, plaintiff-appellee, vs. ENRIQUE DE LEON and PEDRO DE LEON, defendants. ENRIQUE DE LEON, appellant.

FACTS:
On or about January 13, 1913, in Nagsasa, San Antonio, Zambales, surveyor Robert A. Kubillus was killed in his house, which was subsequently burned with his corpse inside. His personal effects were buried nearby. An information for assassination was filed against Enrique de Leon and his son, Pedro de Leon. The case against Pedro was later dismissed for insufficiency of evidence. Enrique de Leon was tried and convicted of assassination with the qualifying circumstance of alevosia (treachery) and the aggravating circumstance of nocturnity, and was sentenced to death. He appealed, arguing that the evidence did not prove his guilt beyond reasonable doubt.

The evidence established that the accused and his son had accompanied the victim to Zambales. After the incident, the accused appeared in Manila in possession of the victim’s knife and gold watch, which he showed to the victim’s wife, Felisa Banal, while confessing to the killing and threatening her not to disclose the information. She nevertheless reported it to the authorities. Investigation at the scene confirmed the burned house, charred human remains, and the victim’s buried belongings (trunk, suitcase, surveying instruments, etc.). The accused was later arrested in Tarlac under an assumed name (Cornelio Vinuya). While under arrest, he voluntarily confessed to a police officer that he killed Kubillus because the latter was “mean” and scolded him daily. At trial, the accused denied the crime, claiming he and his son were out fishing when the house burned and that other persons were with the victim.

ISSUE:
Was the evidence, particularly the extrajudicial confession of the accused, sufficient to sustain his conviction for the crime of assassination beyond reasonable doubt?

RULING:
Yes. The Supreme Court affirmed the conviction. The extrajudicial confession of the accused was admissible and sufficiently corroborated. The Court held that for an extrajudicial confession to be admissible, it must be shown to have been made freely and voluntarily, without compulsion, inducement, or hope of reward. The confession in this case met these criteria, as it was given voluntarily while under arrest without any threat or intimidation.

Furthermore, the confession was corroborated by independent evidence in several material points: (1) the discovery of the burned house at the location described; (2) the finding of charred human remains in the ashes; and (3) the recovery of the victim’s buried personal effects near the scene, exactly as described in the confession. The accused’s possession of the victim’s watch and knife, and his use of an alias after the crime, provided additional circumstantial evidence of guilt.

The Court found no reason to disturb the trial court’s findings and held that the evidence established the guilt of Enrique de Leon for the crime of assassination beyond a reasonable doubt. The penalty of death was affirmed.