Facts:

The case involves the appellants, Juanito Bagasala and his co-accused, Tomas Bagasala, who were charged with robbery with homicide and serious physical injuries. The incident occurred in the early hours of June 10, 1961, at the residence of Macario Ongkit and his wife, Juliana Reginaldo, in Barrio Cadlan, Pili, Camarines Sur. On that fateful morning, Macario was awakened by the barking of their dog and armed himself with a bolo and an iron pipe before confronting five men who had entered their home. Juanito was recognized as one of the assailants, and as he wrested the iron pipe from Macario, he allegedly demanded keys from Juliana while inflicting injury on her. The assault resulted in Juliana's death, confirmed by an autopsy that cited acute internal hemorrhage due to multiple head wounds. Macario, who was severely injured himself and lost a sack of rice worth ten pesos, managed to report the incident after being treated at the hospital. Upon investigation by the Philippin

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Facts:

Incident and Crime

• On the morning of June 10, 1961, Macario Ongkit and his wife, Juliana Reginaldo, were asleep in their residence in Barrio Cadlan, Pili, Camarines Sur.
• The crime occurred at approximately 2:00 a.m. when the barking of their dog alerted them, leading Macario to arm himself with his bolo and an iron pipe.

Entry of the Accused and Crime Perpetration

• Five men forcibly entered the house through the doors leading to the veranda and kitchen.
• Among the intruders, appellant Juanito Bagasala was identified as one who forcibly seized the iron pipe from Macario, while Tomas Bagasala attempted to take away his bolo.
• During the commotion, Macario Ongkit was overpowered—his bolo was wrested away and ultimately used against him, inflicting a wound on the back of his head which rendered him unconscious until nearly dawn.
• Concurrently, Juliana Reginaldo, after being prompted by Ongkit’s command for her key, was beaten with the iron pipe, leading to her grievous injuries and eventual death.

Evidence and Testimonies

• Eyewitness Testimony:
• Macario Ongkit, after regaining consciousness with the help of his son Rafael, reported the incident to the authorities.
• At the scene, the Philippine Constabulary discovered the lifeless body of Juliana Reginaldo, as well as the blood-stained iron pipe and bolo.
• Macario was able to positively identify two of the perpetrators—Juanito Bagasala and Tomas Bagasala—while at the hospital.
• Extra-Judicial Confession:
• Appellant Juanito Bagasala made an extra-judicial statement under oath, admitting his participation in the raid aimed at looting palay from the Ongkit residence.
• This confession was later challenged by the appellant on the grounds that it was obtained under duress involving physical abuse and torture.
• Additional Testimony Regarding Evidence of Torture:
• Juanito Bagasala testified that during his detention he was subjected to physical maltreatment, including being repeatedly struck (boxed) in various parts of his body, being blindfolded, and having water poured on his face.
• Dr. Pedro Villafuerte, the city health officer, corroborated the appellant’s claims by noting several lesions and signs of trauma during an examination conducted seventeen days after detention.

Proceedings and Other Accused

• The information for the offense was filed against five accused, but only Tomas Bagasala and Juanito Bagasala were ultimately adjudged guilty.
• An appeal was taken by both; however, Tomas Bagasala’s appeal was dismissed following his escape from the provincial jail on March 24, 1966, leaving Juanito Bagasala as the sole appellant raising issues on appeal.
• The defense attempted to rely on two lines of argument:
• The allegation that the extra-judicial confession was involuntary due to its extraction by means of torture.
• The use of an alibi, asserting that at the time of the crime, the appellant was in his own house harvesting palay—a version further supported by testimony from his wife.

Evidence Against the Defense of Alibi

• Eyewitness identification from Macario Ongkit and corroboration by other witnesses, including a neighbor and the testimony of the appellant’s daughter, directly linked Juanito Bagasala to the commission of the offense.
• The court noted inconsistencies in the alibi, particularly given the proximity of the locations (the Ongkit residence being only about fifty meters away from the appellant’s house) and the clear positive identification by eyewitnesses.

Issue:

Admissibility of the Extra-Judicial Confession

• Whether the extra-judicial confession of appellant Juanito Bagasala was voluntary or had been obtained by means of torture and other coercive methods, thereby rendering it inadmissible.
• The sufficiency of the proof to demonstrate, beyond reasonable doubt, the guilt of the appellant when the confession is set aside.

Sufficiency of Testimonial Evidence

• Whether the remaining testimonial evidence, including eyewitness accounts by Macario Ongkit, his son, and a neighbor, was competent and credible enough to establish the appellant’s guilt.
• The impact of the conflicting statements (such as that of the appellant’s daughter and the defense’s alibi) on the overall credibility of the evidence.

Effect of the Involuntary Nature of the Confession

• Whether the improper use of an involuntary confession, if that were the case, should lead to the reversal of the conviction.
• Whether the error in admitting the confession affected the substantial evidentiary basis for the conviction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

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