Case Digest (G.R. No. L-26182)
Facts:
The People of the Philippines v. Tomas Bagasala, Juanito Bagasala, Aniceto Ronan, Salvador Ronan and Aniceto Rex, G.R. No. L-26182. May 31, 1971, the Supreme Court En Banc, Fernando, J., writing for the Court.The criminal information charged five persons with robbery with homicide and serious physical injuries for events that occurred on June 10, 1961 in Barrio Cadlan, Pili, Camarines Sur. The People (plaintiff-appellee) prosecuted the defendants; at trial only Tomas Bagasala and Juanito (referred to in the opinion as Juanita) Bagasala were convicted. Of the three other co-accused, the case against Salvador Ronan was dismissed for lack of evidence, Aniceto Ronan was acquitted, and Arsenio Rex was never apprehended.
The factual core: at about 2:00 a.m. the Ongkit spouses were awakened by intruders; Macario Ongkit armed himself and saw five men enter; he positively identified appellant Juanito Bagasala as one who wrested an iron pipe from him and who struck his wife, Juliana Reginaldo, who later died of severe head wounds. Macario was also assaulted and hospitalized; one sack of rice (valued at P10) was taken. Police investigators arrived later that morning; Macario and his son identified the accused at the hospital and the provincial health officer performed an autopsy establishing the cause of death as multiple head wounds and skull fracture.
At the investigation and later proceedings an extrajudicial statement attributed to Juanito Bagasala, signed June 13, 1961, admitted his participation in the raid. At trial the lower court regarded that statement as corroborating the ocular testimony and rejected appellant’s claim that the confession was involuntary. The trial court convicted Juanito of robbery with homicide and serious physical injuries and sentenced him to reclusion perpetua, plus indemnity awards (trial court ordered P5,000 to the heirs and P10 to Macario Ongkit).
Appellant appealed to this Court; both Juanito and Tomas originally took appeals but Tomas escaped from provincial jail on March 24, 1966 and his appeal was dismissed, leaving Juanito as the sole appellant. On appeal Juanito contended (1) the extrajudicial confession was involuntary and obtained by torture; (2) the evidence was insufficient and his alibi should have been accepted; and (3) double jeopardy problems arising from multiplicity of complaints (the latter was dismissed as not serious). The Supreme Court considered t...(Subscriber-Only)
Issues:
- Was the extrajudicial confession of Juanito Bagasala voluntary and admissible in evidence?
- If the confession is inadmissible, is there nevertheless sufficient independent evidence to sustain his conviction for robbery with homicide and serious physical injuries beyon...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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