G.R. No. 169942 - Barangay Dasmarinas vs. Creative Play Corner School

The deceased, Cesareo Tadefa, lived with his wife, Teodora Vergara, in the village of San Jose, Caba, La Union.
The defendant, Mariano Ducusin, was a relative by blood—Teodora’s first cousin and Cesareo’s second cousin—and held the position of second lieutenant in the same village.
Prior to the crime, an illicit affair had developed between the defendant and Teodora Vergara, lasting about a month, despite her initial rejection due to her marital status.

On August 12, 1928, Cesareo Tadefa visited the defendant’s house for his customary haircut and later went to pasture his carabaos on the defendant’s land.
When Cesareo failed to return by nightfall, his wife, Teodora, noticing his absence during routine activities, sought help from nearby relatives.
The disappearance led to an organized search by relatives which culminated the following morning in the discovery of Cesareo’s dead body on a hillside within the defendant’s property.

The body was found lying face down under an adaan tree on a hillside overgrown with cogon grass.
A severed piece of vine, tied around the deceased’s neck with a slipknot, was discovered, with a corresponding length of vine dangling from a branch of the adaan tree, suggesting an attempt to simulate a suicide by hanging.
No additional marks of violence were noted on the corpse beyond the injury inflicted by the vine.

Upon being informed of the discovery, the defendant advised against notifying the authorities immediately, citing concerns about difficulties with body removal and decomposition.
He further orchestrated the removal and burial of the body, advancing money for funeral expenses and securing a burial license.
In town, the defendant misinformed municipal officials by asserting that Cesareo had died of headache and fever, leading to the issuance of a death certificate that incorrectly cited malaria as the cause of death.

Suspicion arose when Teodora Vergara, accompanied by her father, reported her doubts about the defendant’s involvement to the Constabulary on September 17, 1928.
Authorities, acting on these allegations, conducted an investigation that led to the detention of the defendant on September 20, 1928, in the municipal jail of Caba.
While in custody, the defendant was repeatedly interrogated by various officers. He initially made a confession in the presence of Constabulary soldiers, and later repeated and expanded his statements before the justice of the peace (documented in Exhibit D) and Lieutenant Bravo during transit to the provincial jail.
In his confession, the defendant detailed how he had intentionally intoxicated Cesareo Tadefa by offering wine—after having consumed it himself—in order to weaken the victim’s defenses, ultimately strangling him and using a vine to simulate a self-inflicted hanging.
The defendant also mentioned that he had attempted on three separate occasions to kill the deceased prior to the fatal incident, and admitted to having engaged in sexual relations with the deceased’s wife before the crime.

The defendant contended that his initial statements were obtained under duress and torture by Constabulary soldiers, alleging physical abuse including kicks, punches, and the forcible insertion of a twig into his urethra.
However, these claims were rebutted by testimony from the soldiers and other witnesses present during his interrogations, who denied any act of violence or coercion.
The absence of any physical evidence of such torture (e.g., marks on his body or irritations) further undermined the defendant’s assertions.

Testimonies from prosecution witnesses and physical evidence from the crime scene (e.g., the location of the body and the method by which the vine was used) corroborated the defendant’s confession.
The narrative presented by the prosecution aligned with the various statements given by the defendant, despite his later claims of duress.
The incident was further compounded by the defendant’s attempt to manipulate the official record regarding the cause of death.

Whether the trial court erred in giving undue credit to the prosecution’s testimonies over the defendant’s and defense witnesses’ accounts.
The admissibility and reliability of the defendant’s confession given his claims of coercion.

Whether the defendant’s confession—both during the initial police interrogation and his later statements before judicial authorities—was made voluntarily or extracted under duress.
The extent to which alleged acts of torture (as claimed by the defendant) should mitigate the voluntariness of his statements.

Whether the evidence, including the defendant’s own admissions and corroborative physical evidence, conclusively established his guilt beyond reasonable doubt.
The significance of premeditation and the use of elective means (i.e., intoxicating the victim) to determine the character of the crime as murder rather than as a lesser offense.

Whether the aggravating factors such as evident premeditation, the employment of means to weaken the defense, and the crime being committed in an isolated, uninhabited area effectively justified a sentencing to the maximum degree prescribed by law.
The legal sufficiency of the evidence supporting the aggravation of treachery and whether the methods employed directly endangered the independence of the defense by the victim.

Whether the imposition of the death penalty was justified based on the facts and applicable law.
The impact of the lack of unanimity among the judges on sentencing, leading to the modification from a death sentence to life imprisonment.