Case Digest (G.R. No. 80179)
Facts:
People of the Philippines v. Rey Manlapaz y Mando, Cesar Murcia y Magpusao, Renato Santos y Apilanes, G.R. No. 80179, March 19, 1990, Supreme Court Second Division, Melencio‑Herrera, J., writing for the Court.In an information dated December 3, 1981 and filed with the then Court of First Instance of Manila, Branch XXXIII (Criminal Case No. 81-308), Rey Manlapaz, Cesar Murcia (now appellant), and Renato Santos were charged with Robbery with Homicide for the death of Teodoro Tan on September 13, 1981. The trial court found all three guilty and sentenced them to reclusion perpetua in a decision dated February 21, 1981.
During the appeal, Manlapaz escaped from the Ihawig Prison and Penal Farm on February 2, 1986; the Supreme Court, by resolution dated June 15, 1988, dismissed his appeal for that reason and remanded his case to the trial court for execution. Santos also escaped on February 2, 1986 but was recaptured on February 6, 1986; he later wrote the Court requesting withdrawal of his appeal, and the Court, in a resolution dated March 13, 1989, considered his appeal withdrawn and remanded his case for execution. Only Murcia’s appeal remained for adjudication by the Supreme Court.
Factually, Tan was found bloodied along Muelle de Binondo corner Lavezares Streets on the morning of September 13, 1981 and died on September 26, 1981; autopsy showed massive epidural hemorrhage and other blunt-force injuries. Police, relying on an underworld grapevine, identified suspects including a “Boy Kulot” and members of his gang—Manlapaz, Murcia and Santos—and raided Manlapaz’s residence on November 27 or 28, 1981. The three were taken into custody; during investigation the police obtained signed statements (Exhibits B, C and D) which the accused later repudiated at trial as having been extracted under threat and physical maltreatment. In those extrajudicial statements each admitted participation and described substantially similar roles in assaulting the victim; Manlapaz also produced the deceased’s Bally shoes at the raid.
At trial the accused testified they were beaten and coerced into confessing, with Murcia recounting repeated maulings on November 29–December 1, 1981. Notwithstanding the repudiation, the trial court ruled the extrajudicial confessions were voluntary, credited their interlocking details, and convicted the three, finding conspiracy and joint execution of the crime. A prosecution witness, Alipio Cabalag, testified he saw four persons pass hurriedly and that Manlapaz was carrying a pair of shoes; Sgt. Reynaldo Crame testified that Manlapaz surrendered the deceased’s shoes during the raid.
On appeal, Murcia raised four assignments of error challenging the conspiracy finding, the admissibility and voluntariness of the extrajudicial confessions, the admissibility of Manlapaz’s in‑court identification of Murcia as the killer (asserting Murcia had no chance to cross‑examine), and the overall credibility and sufficiency of the prosecution’s evidence. The Solicitor General filed a manifestation urging acquittal on the ground that the extrajudicial confessions were in...(Pro-only)
Issues:
- Were the extrajudicial confessions of the accused admissible where they were obtained during in‑custody interrogation without the presence or assistance of counsel (Section 20, Article IV, 1973 Constitution)?
- Were the extrajudicial confessions rendered inadmissible for being procured through force and intimidation (torture), and did the prosecution rebut the torture allegations?
- Was Manlapaz’s testimony identifying Murcia as the killer admissible against Murcia despite Murcia’s inability to cross‑examine Manlapaz?
- In the absence of the extrajudicial confessions and the challenged testimony, did the remaining evidence suffice to sustain Murcia’s conviction f...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)