Facts:

• The case involves the People of the Philippines as the plaintiff-appellee against accused-appellants Filoteo Manipula, Fernando Azucena, Quirino Azucena, Joaquin Lautriso, and Leopoldo Azucena.
• The incident occurred on March 10, 1965, in Barrio Batete, Concepcion, Iloilo, where spouses Modesto Ayusip and Visitacion Manipula were allegedly killed and robbed of P5,135.20, including P4,000.00 in cash.
• The accused-appellants are related to the victims: the Azucenas are first cousins of Modesto Ayusip, while Filoteo Manipula is the brother of Visitacion Manipula.
• The trial court found the accused guilty of robbery with homicide, imposing the death penalty on Fernando and Quirino Azucena, while acquitting Filoteo Manipula due to insufficient evidence.
• The trial court's decision was based on testimonies, including that of the Chief of Police, who noted Filoteo Manipula's surprise at the victims' deaths, indicating he had no prior knowledge of the crime.
• The prosecution's motion to discharge Leopoldo Azucena as a state witness was denied due to conflicting testimonies.
• The case was elevated for automatic review because of the death sentences imposed on the appellants.

Issue:

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Ruling:

• The Supreme Court reversed and set aside the trial court's judgment, acquitting Fernando Azucena and Quirino Azucena due to insufficient evidence to support their conviction for robbery with homicide.
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Ratio:

• The Supreme Court determined that the prosecution's evidence was insufficient to establish the guilt of the accused beyond a reasonable doubt.
• The Court stressed the necessity of corroboration for confessions, especially in capital cases, noting that Leopoldo Azucena's alleged extra-judicial confession was uncorroborated...continue reading