Case Digest (G.R. No. L-37686)
Facts:
The People of the Philippines v. Benjamin L. Arcenal, G.R. No. L-37686, August 30, 1982, the Supreme Court Second Division, Aquino, J., writing for the Court. The decision was concurred in by Concepcion, Jr., Guerrero, Abad Santos, De Castro, and Escolin, JJ.; Barredo (Chairman), J., was on leave.
Shortly before midnight of September 5, 1972, Edgardo Funa was fatally stabbed on a roadside near a billiard hall in Panabo, Davao del Norte; the autopsy disclosed seventeen stab and lacerated wounds. In the early hours of September 6, 1972, police arrested five men who had been playing billiards with Funa: Navy M. Padilla, Ernesto V. Castro, Benjamin L. Arcenal (the accused-appellant), Ramonit L. Umadhay, and Romeo L. Daquil. All five signed affidavits about the killing sworn before the municipal judge.
The chief of police filed a complaint for homicide against Castro, Arcenal and Padilla; they waived the second stage of the preliminary investigation, and the case was elevated to the Court of First Instance of Davao where the fiscal filed an amended information for murder. After trial the trial court convicted Castro, Padilla and Arcenal of murder, sentenced each to reclusion perpetua and ordered joint indemnity to the heirs of Funa (Criminal Case No. 1050). Only Arcenal appealed.
The convictions of Castro and Padilla rested largely on an extrajudicial confession by Padilla (Exh. B) in which he admitted stabbing Funa and stated that Castro also stabbed him; the police found a hunting knife at Padilla’s boarding house. The trial court convicted Arcenal mainly on an imputation in Padilla’s confession that Arcenal stabbed Funa with a pocketknife (Exh. D). Arcenal denied participation in an affidavit (Exh. E) and at trial. The Solicitor General conceded that the only evidence against Arcenal was the imputation in Padilla’s confession and that there was no eyewitness testimony linking Arcenal to the killing, but argued Padilla’s confession corroborated circumstantial evidence since Arcenal did not explicitly deny the imputation.
Padilla executed an affidavit of retraction dated February 26, 1973, in which he stated Arcenal did not take part and that Padilla himself was the principal; this retraction was filed in the trial court only on September 10, 1973 in support of Arcenal’s motion for reconsid...(Subscriber-Only)
Issues:
- Is Padilla’s extrajudicial confession implicating Arcenal admissible and legally sufficient to convict Arcenal?
- Was Arcenal’s conviction supported by evidence beyond reasonab...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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