Facts:
The People of the Philippines v.
Ramiro Alegre y Cerdoncillo,
Mario Comayas y Cudillan,
Melecio Cudillan y Arcillas, and
Jesus Medalla y Cudillan arose from the discovery on July 26, 1966 of the body of Adelina Sajo inside her house in the Maravilla compound, Ignacio Street, Pasay City, the necropsy placing the cause of death as asphyxia by manual strangulation and the time of death between eighteen to twenty-two hours before 12:30 p.m. of July 26, 1966. The victim’s bedroom was ransacked and jewelry was missing. Appellant
Ramiro Alegre was a lodger in the house and was briefly taken to the Pasay police for inquiry but released for lack of evidence.
Melecio Cudillan was arrested in Tacloban for pawning a bracelet taken from the victim and executed sworn extrajudicial statements in Tacloban (July 29, 1966) and in Pasay (July 31, 1966, sworn August 1, 1966) in which he admitted participation and implicated others including
Jesus Medalla, “Rami” (identified as
Ramiro Alegre) and
Mario (identified as
Mario Comayas). An Information for Robbery with Homicide was filed and, upon trial in the Court of First Instance of Rizal, the trial court convicted
Melecio Cudillan,
Jesus Medalla,
Ramiro Alegre and
Mario Comayas of Robbery with Homicide, imposed the penalty of death, ordered joint and several indemnity of P350,000 for unrecovered jewelry and P12,000, and directed elevation of the case to the Supreme Court. During the appeal
Melecio Cudillan died on arrival at the New Bilibid Prison Hospital on August 16, 1970 and the prosecution against him was dismissed on August 29, 1974; this decision addressed the appeals of
Ramiro Alegre,
Mario Comayas and
Jesus Medalla. At trial the prosecution relied mainly on the extrajudicial confessions of
Melecio Cudillan and on the testimonies of Sgt. Mariano Isla, who testified that
Melecio pointed to the three appellants while in police custody, and of inmate Hernando Carillo, who testified that each appellant admitted participation while detained; appellants offered alibi and work records and repudiation of the sworn statements by
Melecio in open court.
Issues:
Were the extrajudicial confessions of
Melecio Cudillan admissible and competent proof against appellants
Ramiro Alegre,
Mario Comayas, and
Jesus Medalla in the absence of independent evidence of conspiracy?; Could the silence of appellants when allegedly pointed out by
Melecio Cudillan while under police custody be treated as a tacit admission of guilt?; Were the testimonies of Sgt. Mariano Isla and inmate Hernando Carillo sufficient to sustain conviction after excluding the extrajudicial confessions?
Ruling:
Ratio:
Doctrine: