G.R. No. L-65165 - People vs. Mateo

On the early morning of October 9, 1981, the body of Manuel Pascual, a 34-year-old tricycle driver, was found near a bridge or creek east of the Mariano Marcos State University Compound in Laoag City.
The victim sustained thirteen incised and stab wounds, suggesting a violent assault, and his tricycle was later located on the roadside.
A bolo was discovered a few meters from the tricycle in a field planted with kangkong, indicating the use of multiple weapons.

On October 23, 1981, five suspects—Fidel Mateo (20), Elmer Dajugar (18), Rene Ambrocio (15), Florante Martinez (15), and Edwin Aglugob (15)—were arrested.
Their extrajudicial confessions were taken (as evidenced by Exhibits H to L), which provided a detailed account:

The five accused picked up Pascual’s tricycle at about 5:00 p.m. on October 8, 1981, at the bus terminal.
They went to Juman’s Eatery in Pasiocan, Bacarra, Ilocos Norte, where they drank gin with the victim, leading to their drunken state.
Mateo allegedly conceived the idea to kill Pascual due to a prior incident where Pascual had boxed him in July 1981.

After drinking, they returned to Laoag City with Pascual driving the tricycle.
They stopped at Barangay Barit on the street leading to the city mayor’s residence.
Dajugar reportedly boxed Pascual while Martinez stabbed him, prompting Pascual to flee and shout for help.
The accused caught up with him, repeatedly stabbing him until he collapsed on the concrete road.
Dajugar and Martinez then loaded the victim onto his tricycle and disposed of his body near the state university.

Froilan Ramirez, 16, testified that at around 9:00 p.m. on October 8, 1981, he observed Pascual being chased by Mateo, Aglugob, and a third person near Barrio Pandan, Laoag City.
Ramirez noted that a tricycle with an unknown driver and passenger was following the group, and the accused overtook Pascual and used repeated stabs and hacks against him.

Corroboration: The eyewitness account, including a diagram (Exhibit N), confirmed key elements of the suspects’ confessions.

The five accused were charged on November 12, 1981, with murder qualified by treachery, evident premeditation, and with aggravating circumstances such as abuse of superior strength, nighttime conditions, and drunkenness.
Plea Adjustments:

At the hearing on July 20, 1983, Ambrocio, Aglugob, and Martinez (all fifteen years old at the time) initially pleaded not guilty but then changed to guilty—although Martinez later reverted to not guilty.
The trial court found Ambrocio and Aglugob guilty but suspended their sentences by committing them to custody under the Ministry of Social Services and Development.

The trial court proceeded with the trial against Mateo, Dajugar, and Martinez, eventually finding them guilty of murder.

Dajugar, the only appellant, challenged the admission of his confession on the grounds of alleged maltreatment and insufficient advisement regarding his right to counsel as required by constitutional provisions and relevant procedural rules.
Unlike co-accused whose confessions included an admonition about hiring a lawyer if indigent, Dajugar was only informed of his right "to remain silent and to hire a lawyer," a point of contention raised in his appeal.
Despite these procedural issues, the corroborative extrajudicial confessions from the co-accused and the eyewitness testimony served as circumstantial evidence of his participation.

Whether Dajugar’s confession should be excluded due to claims of maltreatment and the failure by the investigator to fully apprise him of his right to counsel as mandated by constitutional and statutory requirements.
Whether the incomplete advisory in Dajugar’s case affects the overall evidentiary basis against him, considering the corroborating confessions of his co-accused.

Whether the extrajudicial confessions of the co-accused, which share essential details in common with Dajugar’s confession, sufficiently establish his complicity in the murder despite procedural irregularities.
The extent to which the eyewitness testimony supports the conclusion that Dajugar was a co-principal in the commission of the crime.

Whether aggravating circumstances (such as abuse of superior strength) were proven adequately to qualify the murder charge, and if the allegations of treachery and evident premeditation hold under scrutiny.
Whether Dajugar’s age—being below eighteen at the time of the crime—and his state of drunkenness serve as mitigating factors warranting a reduction in his penalty.