G.R. No. 204218 - Nagano vs. Tanjangco

On June 9, 1978, the brutally beaten corpses of Amparo Vda. de Bantigue and Luisa Jara were discovered at Malvar Street, Puerto Princesa City. Both women were well-known and loved in their community.
Amparo and Luisa were found lying on one bed in Amparo’s bedroom; Luisa was dressed only in her underwear with dried blood on one hand. Both showed multiple severe cranial fractures and stab wounds.
The wounds were inflicted with great force and reflected intense hatred.

Felicisimo Jara, Reymundo Vergara, and Roberto Bernadas were charged with robbery with homicide in Criminal Case No. 2564.
In a companion case (Criminal Case No. 2565), Felicisimo Jara was separately charged with parricide for the killing of his wife, Luisa Jara; Vergara and Bernadas were charged with homicide.
The prosecution alleged the accused conspired, gained entry through window, and killed the victims with a hammer and scissors, followed by robbery of piggy and buddha banks.
Aggravating circumstances included recidivism (Jara), treachery, nighttime commission, crime in the dwelling, and reward given to Vergara and Bernadas.

Accused Vergara and Bernadas were apprehended, later confessing extra-judicially before police and provincial commanders, identifying Jara as the mastermind promising them P1,000.00 each.
Their confessions were subscribed and sworn before city fiscals. A public re-enactment of the crime was conducted with their participation, based on the confessions.
Felicisimo Jara denied involvement, presenting an alibi that he was asleep at his stepdaughter’s house during the killings.

Vergara and Bernadas retracted their confessions during preliminary investigation, claiming coercion, lack of counsel, and involuntariness.
The accused challenged the admissibility of the extra-judicial confessions and re-enactment evidence.
Felicisimo Jara asserted alibi and denied involvement in both cases.

The trial court admitted the extra-judicial confessions as evidence against all accused.
All three were convicted; Jara and co-accused sentenced to death for robbery with homicide, Jara to death for parricide, and the other two to imprisonment for homicide.
Orders for indemnity to the heirs of both victims totaling P30,000.00 were imposed.

Autopsy reports detailed multiple comminuted-depressed skull fractures and stab wounds as cause of death for both victims.
Blood stains on Jara’s clothing and eyeglasses were scientifically tested and confirmed as human blood (Type B), inconsistent with his claim of chicken blood during market errands.
Witnesses testified to Jara’s frequent quarrels and animosity with his wife, who lived with Amparo as “husband and wife,” and to Jara’s behavior at the crime scene (lack of sorrow).
The murder weapon (hammer) was identified as belonging to Luisa Jara.

Whether the extra-judicial confessions of Reymundo Vergara and Roberto Bernadas were voluntary and admissible, given the absence of counsel and allegations of coercion.
Whether the extra-judicial confessions of co-accused (Vergara and Bernadas) are admissible against Felicisimo Jara.
Whether the evidence, direct or circumstantial, is sufficient to establish guilt beyond reasonable doubt for all accused.
Whether conspiracy was proven beyond reasonable doubt.
Whether the re-enactment and taped confessions were improperly admitted.
Whether improperly identified photographs should have been admitted.