Case Digest (G.R. No. L-28232)
Facts:
The People of the Philippines prosecuted Jaime Jose y Gomez, Basilio Pineda, Jr., Edgardo Aquino y Payumo and Rogelio Canal y Sevilla for forcible abduction with rape arising from the June 26, 1967 abduction and successive rapes of complainant Magdalena "Maggie" de la Riva; Pineda pleaded guilty, the others pleaded not guilty, and on October 2, 1967 the trial court convicted all four, sentenced each to death, ordered indemnity of P10,000, and ordered confiscation of the car used. The case was appealed by Jose, Pineda and Aquino and was subject to automatic review as to Canal; intervenor Filipinas Investment & Finance Corporation later claimed the car by virtue of a prior chattel mortgage and replevin judgment.
Issues:
- Did the evidence prove beyond reasonable doubt that the appellants committed forcible abduction with rape under Art. 335 as amended by Republic Act No. 4111?
- Were the extrajudicial statements of Jose and Canal involuntary or rendered inadmissible because the accused lacked counsel during custodial interrogation?
- Could the car used in the crime be confiscated despite a prior chattel mortgage and assignment in favor of a third party?
Ruling:
The Court affirmed the convictions but modified the judgment: it found Jaime Jose y Gomez, Basilio Pineda, Jr., and Edgardo P. Aquino guilty of the complex crime of forcible abduction with rape and guilty of three other rapes, and imposed four death penalties on each; it dismissed the case as to Rogelio Canal y Sevilla insofar as criminal liability due to his death. The Court set aside the trial court's order of confiscation and ordered delivery of the car to intervenor Filipinas Investment & Finance Corporation pursuant to the replevin judgment; it also ordered joint and several indemnity of P10,000 for each offense (total P40,000) and allocation of costs.
Ratio:
The Court found the complainant's testimony, corroborated by medico-legal findings of external and genital injuries and by voluntary extrajudicial admissions, reliable and persuasive against the implausible defense story of a consensual striptease. The Court held that the extrajudicial statements were made voluntarily and that the absence of counsel during custodial interrogation did not render them inadmissible under local law and procedural rules then in force. On penalties, the Court applied Art. 335 (as amended by R.A. No. 4111) and, relying on the conspiracy doctrine and sentencing precedents, sustained the imposition of multiple death penalties for distinct capital felonies; conversely, under Art. 45 the Court prohibited confiscation of property where it belonged to a third party not liable for the offense and affirmed delivery of the car to the mortgagee whose chattel mortgage and assignment predated the crime.
Doctrine:
- The uncorroborated but credible testimony of the rape victim may suffice when corroborated by physical and medico-legal evidence.
- Extrajudicial confessions are admissible if shown to be voluntary and not obtained by force or intimidation.
- The right to counsel before trial does not automatically render custodial statements inadmissible where local constitutional and procedural rules are satisfied.
- A plea of guilty admits the material allegations of the information, including aggravating circumstances.
- Once conspiracy is established, each conspirator is liable for the felonious acts of the conspiracy and multiple penalties may be imposed for distinct capital offenses.
- Under Art. 45, instruments of crime shall not be confiscated if they are the property of a third person not liable for the offense; prior duly registered chattel mortgage and assignment prevail over confiscation.