Case Digest (G.R. No. L-24484)
Facts:
The People of the Philippines v. Ramon Narciso y Contreras, et al., G.R. No. L-24484, May 28, 1968, the Supreme Court En Banc, Angeles, J., writing for the Court.The criminal information, filed July 12, 1961, charged four detained prisoners — Ramon Narciso, Elias Gloria, Francisco Celso and Rufino Pena y Guevarra — with the murder of fellow detainee Roberto Monreal inside Cell 2-A of the City Jail of Manila on the night of July 10, 1961. All pleaded not guilty at arraignment on July 17, 1961. The case was tried in the Court of First Instance of Manila (Criminal Case No. 5871), where the prosecution offered testimony from the medico-legal officer, police investigators and the lone eyewitness, prisoner Bernardo Villalon, as well as exhibits including the necropsy report, a blood-stained piece of wood and a blood-stained blanket, and extra-judicial statements of the accused (Exhs. J, K, L, M, N).
During pretrial proceedings the trial court dismissed the case against Francisco Celso for insufficiency of evidence (order of Aug. 7, 1964). Elias Gloria escaped confinement and remained at large; Ramon Narciso later testified but died of natural causes (Feb. 10, 1965), and the case as against him was dismissed. Trial proceeded against the sole remaining defendant, Rufino Pena, who testified denying participation and claiming his extra-judicial statement (Exh. K) was obtained under torture by police at MPD headquarters.
The trial court found corpus delicti established, admitted the extra-judicial confessions (including those of co-accused), credited Pena’s confession as voluntary, and on March 25, 1965 convicted Rufino Pena of murder and sentenced him to death with civil indemnity and costs. Because a death penalty was imposed, the judgment was brought...(Subscriber-Only)
Issues:
- Were the extra-judicial confessions of co-accused (Exhs. J, L, M) admissible against Rufino Pena?
- Was Rufino Pena’s own extra-judicial confession (Exh. K) voluntary and therefore admissible?
- Did the evidence suffice to convict Rufino Pena of consummated murder, or should the conviction be for a lesser offense?
- Did the trial delays and frequent changes of appointed coun...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)