Case Digest (G.R. No. L-4847)
Facts:
People of the Philippines v. Moros Ansang, G.R. No. L-4847, May 15, 1953, the Supreme Court En Banc, Jugo, J., writing for the Court.
The criminal information filed in the Court of First Instance of Zamboanga charged Moro Ansang, Moro Jubail and Moro Jaho with multiple murder. At trial the court acquitted Jaho but convicted Ansang and Jubail; each convicted defendant was sentenced to suffer reclusion perpetua, to pay the heirs of each victim an indemnity of P2,000 (jointly and severally), to suffer accessory penalties, and each to pay one-third of the costs. Ansang and Jubail appealed.
The underlying facts, as found by the trial court and supported by evidence, began in October 1949 when Ansang complained to the chief of police of Maluso that Moro Berto was removing coconuts from Ansang’s plantation; the chief advised Ansang to seek redress from the provincial fiscal, but Ansang was unable to see that officer and the alleged taking continued. On October 7, 1949, Jubail, Ansang’s foster son, saw Berto and three companions loading seven sacks of copra and observed that they sailed that same day to Isabela.
A few days later witnesses saw Jubail and Jaho boarding another vinta; Jubail carried three home-made bombs and told bystanders they were going fishing. When Jubail and Jaho returned they had neither bombs nor fish. Berto and his three companions were thereafter not seen or heard from; pieces of Berto’s vinta were later found on the shore of the Island of Pilas. Authorities investigated and arrested Ansang, Jubail and Jaho.
Each of the three accused made extrajudicial written confessions. Ansang’s confession (Exhibit B) stated that, because Berto and his companions had taken copra from his plantation, he ordered Jubail to follow and kill them. Jubail’s confession recounted that, acting on Ansang’s order and carrying three bombs, he and Jaho followed Berto’s vinta and that Jubail ignited and threw the bombs, resulting in the destruction of the vinta and the disappearance of the four passengers. Jaho’s confession admitted he served as helmsman and said he was unaware of Jubail’s intent to commit a crime; he said that, had he known, he would not have accompanied Jubail.
At trial none of the three accused questioned the voluntariness of their confessions; they generally denied commission of the crime but did not allege coercion, torture or inducement. Appellants argued that a conviction resting on an extrajudicial confession requires independent proof of the corpus delicti; the trial court found such corroboration in the motive (An...(Subscriber-Only)
Issues:
- May a conviction be based upon an extrajudicial confession absent proof of the corpus delicti independent of the confession?
- Should the indemnity fixed by the trial court be modified ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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