G.R. No. L-22766 - Surigao Electric Co., Inc. vs. Municipality of Surigao

The case involves charges of double murder against a group of accused, including Artemio Garcia, Marcelino Tugade, Geronimo Buenaflor, Casimiro Lopez, Francisco Raquem, Pastor Sison, Pedro Ballares, Marcelo Barreto, and Jose Ruiz.
The murders in question were committed against Rafael Birog and Mariano Birog, allegedly killed by having their necks cut in an uninhabited location with evident premeditation and treachery.
Marcelo Barreto, though at large during the trial, played a role in the commission of the crime alongside the accused.

The investigation was prompted by information regarding the theft of carabaos in Alaminos, Pangasinan, which drew the attention of Mayor Agapito Braganza.
Suspicion initially fell on Francisco Raquem, who denied any involvement.
Mayor Braganza then enlisted the help of Artemio Garcia, an agent of the Philippine Constabulary, to further probe the matter.

On January 18, 1949, Garcia, together with Raquem, Tugade, and Ruiz, proceeded to the residence of Rafael Birog in sitio Papaya, Mabini, Pangasinan.
Upon arrival, they encountered several individuals, including Cecilia Cardenas, Aquilina Birog (Rafael’s wife and daughter, respectively), Leon Bona, and Geronimo Buenaflor.
Garcia, armed with a revolver, directed his companions to detain and investigate Leon Bona and others.
The group transitioned to the house of barrio lieutenant Casimiro Lopez, where detailed interrogations occurred regarding the alleged cattle rustling by Rafael and Mariano Birog.
After mock investigations and maltreatment, the accused eventually reconvened at the house of Rafael Birog where further actions culminated in the decision to “liquidate” Rafael and Mariano Birog.
Garcia ordered Pedro Ballares, Jose Ruiz, and Marcelo Barreto to remove the two Birogs to an undisclosed location, from which they were never seen again.

The disappearance of Rafael and Mariano Birog was reported by Cecilia Cardenas, resulting in an investigation by Inspector Queruben Manipon of the Intelligence Division of the Philippine Constabulary.
Appellants Pedro Ballares and Jose Ruiz later provided confessions detailing their active participation:

Their admissions were recorded in affidavits and corroborated by the discovery of bones and strands of hair from two male individuals at the indicated location.

Witness testimonies by Leon Bona, Francisco Raquem, Cecilia Cardenas, and Aquilina Birog confirmed that on January 18, 1949, the two victims were immobilized, removed, and never returned after being subjected to maltreatment and interrogation.

The appellants contended that the prosecution had failed to prove the corpus delicti, alleging that while bones and hair were identified, their origin could not be conclusively linked to Filipino victims.
It was further argued that the reenactment of the crime by Ruiz and Ballares was involuntary—done merely to avoid further maltreatment after prolonged incommunicado detention and physical hardship.
Additional contentions involved assertions regarding the impossibility of the accused traveling between Mount Dimalagan and Mabini in the alleged time frames and inconsistencies in the testimonies concerning the investigation on January 19, 1949.

Whether the corpus delicti (the fact of death) had been adequately established and proven beyond reasonable doubt despite the challenges regarding the identification of the recovered bones and hair.
Whether the confessions of appellants Jose Ruiz and Pedro Ballares were admissible, particularly given the allegations of being obtained under duress and continuous maltreatment.
Whether the physical impossibility claimed by the appellants concerning the travel time between the crime scene in Mount Dimalagan and the municipality of Mabini affected the reliability of the witness testimonies and the chronological narrative of the events.
Whether the evidence sufficiently implicated appellant Artemio Garcia as an active principal in the commission of the murders, notwithstanding his defense that he had merely conducted an investigation.