Case Digest (G.R. No. L-34248)
Facts:
The People of the Philippines v. Roberto Molleda y Gerona alias Tikboy, et al., G.R. No. L-34248, November 21, 1978, Supreme Court En Banc, Santos, J., writing for the Court.The prosecution charged Roberto Molleda, Virgilio Baluyot, Reynaldo Nicolas and Evelyn Duave with murder in an information filed April 6, 1971. The information alleged that on or about January 7, 1971 in Manila the accused, conspiring together with others, used superior strength and the aggravating circumstance of deceit to kill Alfredo Bocaling by stabbing and mauling him. The Circuit Criminal Court, Manila (Judge Manuel R. Pamaran) tried the case.
At trial the People presented an eye‑and‑ear witness, Ramon Ching, medico‑legal testimony (Dr. Abelardo Lucero) describing multiple stab and blunt injuries that caused death, investigative testimony (Detective Amador Jose, Patrolman Nestor Miguel), and as exhibits the postmortem report and extra‑judicial written statements of Molleda (Exh. G), Baluyot (Exh. H) and Nicolas (Exh. I). The defense called the accused and produced identity and alibi documents. The factual narrative at trial was that Ching and Bocaling, after accepting an invitation from Duave and another woman (Melinda), were led to a house on Suter Street where, after a period of drinking, Duave allegedly signaled or summoned Molleda, Baluyot and Nicolas; when the two men later walked away they were set upon, Bocaling fell and was repeatedly beaten and stabbed until he died; Ching escaped and later reported the killing. Molleda, Baluyot and Nicolas each gave written statements during investigation describing their participation; the accused fled to Olongapo after the incident and were later apprehended there.
On June 11, 1971 the trial court convicted all four of murder qualified by taking advantage of superior strength and by deceit, and sentenced each to death (plus damages). The court admitted the extra‑judicial confessions against their authors and, as circumstantial evidence, against Duave because the confessions were largely corroborative and she was present when they were made.
The case reached the Supreme Court by mandatory review (automatic appeal) required in capital cases. The parties filed briefs and the Solicitor General later suggested the evidence might better support homicide rather than murder. The Supreme Court, sitting En Banc, affirmed the convictions of Molleda, Baluyot and Nicolas but, because only eight Justices concurred as to those convictions and only seven as to Evelyn Duave...(Subscriber-Only)
Issues:
- Were the extra‑judicial confessions (Exhs. G, H, I) voluntarily given and admissible in evidence?
- Could the confessions of Molleda, Baluyot and Nicolas be admitted as evidence against co‑accused Evelyn Duave?
- Was the testimony of the eye‑and‑ear witness Ramon Ching credible and properly accorded weight?
- Did the trial court properly reject the accuseds’ defenses (alibi, non‑participation) and give probative value to their flight to Olongapo?
- Did the evidence establish murder qualified by taking advantage of superior strength and aggravated by deceit (craft), or was the killing only homicide?
- Were the accused denied due process when the trial court ap...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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