Case Digest (G.R. No. 188078)
Facts:
In The People of the Philippines vs. Francisco Galit, G.R. No. L-51770, decided March 20, 1985 by the Supreme Court En Banc under the 1973 Constitution, the accused, a construction worker from Marikina, was picked up on suspicion of killing a widow, Natividad Fernando, during a robbery in Montalban, Rizal on August 23, 1977. After two weeks in the custody of the Montalban police and referral to the National Bureau of Investigation, he was interrogated almost continuously for five days by NBI Agent Carlos Flores and associates. Despite consistent denials, investigators “maul[ed] and torture[d]” him—beatings, suffocation with a rag, immersion of his face into a toilet bowl—until he signed a prepared salaysay and took part in a forced photo reenactment. No other evidence linked him to the crime. He was charged with Robbery with Homicide before the Circuit Criminal Court of Pasig, tried, and on August 11, 1978 found guilty based solely on his coerced confession and sentenced to deatCase Digest (G.R. No. 188078)
Facts:
- Crime and Investigation
- On August 23, 1977, Mrs. Natividad Fernando, a 70-year-old widow, was found dead in her Montalban, Rizal, home with seven wounds from a blunt instrument.
- More than two weeks later, construction worker Francisco Galit was picked up by Montalban police on suspicion of robbery-homicide and referred to the NBI on September 8, 1977, for further investigation.
- Custodial Treatment and Confession
- For five days, Galit was detained and interrogated without counsel, beaten repeatedly, forced to inhale human waste, and otherwise tortured until he conceded guilt and signed a prepared confession (Salaysay) on September 9, 1977.
- Against his will and without legal assistance, he later participated in photographed reenactment of the crime.
- Trial Court Proceedings
- An information for robbery with homicide was filed in the Pasig Circuit Criminal Court, charging Galit and two unknown accomplices with breaking into the victim’s home, killing her to facilitate robbery, and stealing cash and valuables.
- Prosecution evidence consisted of:
- The coerced extrajudicial confession.
- Testimony of Florentino Valentino, who claimed to have overheard Galit admit the crime at their shared residence in Marikina and observed him carrying a bag of coins.
- Medical-legal reports and photographs of the victim’s wounds.
- Defense evidence asserted Galit’s alibi in Marikina, denial of participation, and challenged the admissibility of the confession as obtained by torture and without counsel.
- Trial Court Decision
- On August 11, 1978, immediately after defense evidence, the trial court convicted Galit of robbery with homicide, imposed death penalty, ordered indemnification of ₱110,000 to the heirs, and costs.
- No physical evidence linked Galit to the crime scene; conviction rested primarily on the extrajudicial confession and hearsay.
Issues:
- Whether the extrajudicial confession of Francisco Galit was voluntarily made and admissible in evidence.
- Whether the prosecution presented sufficient competent evidence to sustain Galit’s conviction for robbery with homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)