Case Digest (G.R. No. L-2623)
Facts:
The People of the Philippines v. Arsenio Banayad, G.R. No. L-2623, April 26, 1950, the Supreme Court En Banc, Reyes, J., writing for the Court.The respondent in the prosecution was The People of the Philippines (plaintiff and appellee); the appellant was Arsenio Banayad (defendant and appellant). Banayad was tried before the Court of First Instance of Quezon for the murder of Gregorio Reyes (Uy Un).
On the night of October 14, 1946, between 9 and 10 p.m., Gregorio Reyes Uy Un was asleep on the floor of a house in Barrio Vigo Kantidang, San Narciso, Quezon, when two .30-caliber carbine shots were fired from outside; both bullets traversed his body with nearly parallel trajectories and proved fatal. Other occupants were awakened by the shots but did not see the shooter. The municipal police, who investigated the next morning, found two .30-caliber slugs on the mat near the body and two empty .30-caliber carbine shells under the house siding; a small opening was discovered in the siding that could admit the barrel of a gun.
During the municipal investigation the chief of police saw Jose Carbido carrying a carbine; Carbido said he had borrowed it from appellant at the order of his brother Antonio. Examination of the carbine revealed a piece of dried coconut leaf stuck between the barrel and the stock tip, and because the carbine was unlicensed it was confiscated and appellant was summoned for questioning. On the morning after the crime appellant gave a statement (Exhibit 1) denying involvement and saying the gun had been given to him months earlier and was borrowed on October 15 by Carbido; he was ordered released.
The military police later questioned appellant. On November 2, 1946, appellant gave a second statement (Exhibit 2) that he had gone hunting that evening and had been told by Leoncio Hanabaab that Hanabaab had shot Uy Un. Five days later appellant gave a third statement (Exhibit 5) implicating the Pabon brothers as the shooters and claiming he was forced to accompany them and loan his carbine. Subsequently, before the provincial MPC commander, appellant repudiated the prior statements and made a written confession (Exhibit H, Exhibit C) admitting that he himself fired the two shots into Uy Un at about 10 p.m. on October 14, 1946, asserting he did so at the direction of Mayor Gaudencio Medinilla who had promised reward and protection. The confession was reduced to writing, signed, sworn to before the clerk of court, and later reaffirmed to NBI agents in custody after they removed other persons from the cell and assured him they represented the Department of Justice.
Additional evidence: Simeona Montero testified she saw appellant pass by mounted on a carabao before 9 p.m. toward the scene; two .30-caliber slugs and shell casings and the piece of coconut leaf tied the carbine to the siding of the victim’s house; appellant had been previously convicted (Court of First Instance of Tayabas, confirmed by Court of Appeals) in 1938–1940 for theft upon complaint of the deceased, supplying a possible motive.
At trial, appellant denied shooting Uy Un, asserted his confession was coerced, and produced two alibi witnesses—Maximo Espinosa and Anacleto Requeron—who said they spent the night at his house. The trial court of Quezon found the alibi witnesses' testimony unconvincing, gave weight to app...(Pro-only)
Issues:
- Was appellant’s written confession admissible and voluntary such that it could be the basis for conviction?
- Were there sufficient corroborating facts and circumstances to support conviction for murder despite the confession being central to the prosecution’s case?
- Did appellant’s alibi create reasonable doubt requiring ...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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