Case Digest (G.R. No. L-36613-14)
Facts:
People of the Philippines v. Restituto Jimenez, Pedro Naval, Macario Francisco, Mamerto Mendoza, and Mario Salazar, G.R. No. L-36613-14, July 24, 1981, the Supreme Court En Banc, Per Curiam, writing for the Court.The case arose from two informations filed in the Circuit Criminal Court of Pasig, Rizal: Criminal Case No. CCC‑VII‑727 for Kidnapping with Murder (later framed as Murder with Kidnapping with Direct Assault upon Agents of a Person in Authority) and Criminal Case No. CCC‑VII‑726 for Robbery. The offences stemmed from the February 10, 1971 killing of two NBI agents, Rogelio Domingo and Antonio Dayao, during a raid on a marijuana plantation allegedly protected by the bandit Leonardo Manecio (@ Nardong Putik) and his group, which included several of the accused.
At trial the prosecution relied principally on extrajudicial confessions by several accused and on forensic and documentary evidence establishing the deaths of the two agents. The three accused arraigned and tried together—Restituto Jimenez, Pedro Naval and Macario Francisco—were convicted on October 15, 1971 of Kidnapping with Murder with Direct Assault upon Agents of a Person in Authority and sentenced to death; they were also convicted in the robbery case in the same judgment. Mario Salazar, tried separately after his later arrest, was convicted in judgments dated November 11, 1972, and likewise sentenced to death; he filed a notice of appeal for the robbery conviction but the records were not elevated, deemed abandoned.
One co‑accused, Mamerto Mendoza, was acquitted for insufficiency of evidence. During the pendency of appeals Francisco escaped and remained at large; Jimenez died in prison (June 28, 1978), and the Court later dismissed the appeal as to his criminal liability only. The appellants challenged primarily the admissibility a...(Pro-only)
Issues:
- Were the appellants’ extrajudicial confessions admissible as voluntary statements and sufficient, together with proof of corpus delicti, to support conviction?
- Did the appellants’ alibi defenses and the testimony of their corroborative witnesses create reasonable doubt requiring acquittal?
- Was the proper legal characterization of the crime Kidnapping with Murder or Murder with Direct Assault upon Agents of a Person in Authority...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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