Case Digest (G.R. No. L-17465)
Facts:
People of the Philippines v. Nicomedes Castro, et al., G.R. No. L-17465, August 31, 1964, the Supreme Court En Banc, Per Curiam. The appellants are Nicomedes Castro, Godofredo Basuel, and Rufino Cinco, accused in the proceedings below of the double murder of Cabugao Mayor Lucio Zabala and his wife Petra Serna on 21 July 1959.
On the evening of 21 July 1959 the Zabala family were dining in a well‑lit ground‑floor dining room when two armed men entered and fired at the mayor and his wife; both victims died (autopsy and medical evidence identified multiple gunshot wounds and fatal injuries). Present and testifying at trial were several family members, notably Luzvimin Zabala (the mayor’s 23‑year‑old daughter), who sat near the dining‑room door and later identified one assailant, and Libert Zabala (a ten‑year‑old son) who observed the events and pointed out the assailants’ direction of exit.
Police and PC forces conducted searches overnight and over the following days. On 1 August 1959 Luzvimin identified one of the suspects as Nicomedes Castro in a confrontation at the town puericulture center. Castro initially gave a signed statement denying participation and asserting an alibi, but on 3 August 1959 he signed a detailed four‑page confession at the PC Task Force Zebra headquarters in Vigan which implicated himself and others, described planning discussions, named alleged paymasters and accomplices, and detailed post‑crime movements. The confession bore a jurat before the Justice of the Peace and a subsequent jurat by the provincial fiscal; it included an express denial that the declarant had been forced, threatened or promised anything. Similar signed confessions were obtained from Rufino Cinco and Godofredo Basuel, each sworn before a fiscal or justice of the peace and later filed in court.
A diary found in Castro’s possession had its page for 21 July 1959 missing. Ballistic tracing and searches were conducted (one rifle found where Castro had said a rifle was left was forensically excluded as the murder weapon). On 5–6 August 1959 informations were filed in the Court of First Instance of Ilocos Sur (Criminal Case No. 3714) charging the appellants with double murder; Castro, Cinco and Basuel were arraigned on 21 August 1959, pleaded not guilty, and submitted to medical/physical examination. The trial court convicted the three accused and imposed the death penalty.
The appellants raised fourteen assigned errors on appeal, grouping challenges on (a) the admissibility and voluntari...(Subscriber-Only)
Issues:
- Were the extrajudicial confessions of the accused admissible and voluntary under the Constitution?
- Was the eyewitness identification by Luzvimin (and supporting testimony) sufficient to connect the accused to the murders?
- Could a conspiracy be inferred so as to render each accused liable for the acts of his companions?
- Did the appellants’ alibi evidence create reas...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)