Case Digest (G.R. No. L-30577)
Facts:
The People of the Philippines v. Ricarte Obedoza, et al., G.R. No. L-30577, July 24, 1981, Supreme Court Second Division, Concepcion, Jr., J., writing for the Court.
On the night of May 28, 1967, at Barrio Salagusog, Cuyapo, Nueva Ecija, several armed men stole four carabaos and one cow from Maximiniano Cabangcala; when the victim heard gunfire he jumped from a window and received pellet wounds to his right leg that later became gangrenous and caused his death on June 13, 1967. Medical testimony established the wounds were consistent with a .12-gauge shotgun and that amputation had been advised but refused. Certificates of ownership for the animals were offered in evidence.
Police investigation did not immediately identify suspects. In October 1967, after the arrest of Lauro Alcantara in Pangasinan, Alcantara allegedly made an extra-judicial confession implicating himself and others (including Ben Bocasas, Lucio Paldeng, Londring Martinez, and Jessie Quitan) in the theft and naming Ambrocio Sumalbag as informer. Ricarte Obedoza (alias Alfonso Obedoza) was later found confined in the Balungao jail and likewise allegedly made a confession corroborating Alcantara’s account. Re-enactments and a sketch (Exhibit "G") were produced by the police.
A complaint for robbery in band with homicide was filed November 22, 1967 (amended November 27), and an information was filed March 18, 1968, charging numerous persons; however, only Londring (Eufemiano) Martinez, Ambrocio Sumalbag, and Lauro Alcantara were arraigned and tried, the others remaining at large. After trial, the Court of First Instance of Nueva Ecija convicted Alcantara, Martinez and Sumalbag on March 26, 1969 and sentenced each to life imprisonment, imposed accessory penalties, and ordered indemnity to the heirs of the victim.
Appellants Ambrocio Sumalbag and Londring Martinez appealed the conviction. The prosecution’s case rested heavily on the extra-judicial confessions of Alcantara and Obedoza, testimony of a few eyewitnesses who did not identify the culprits at the time of the incident, police witnesses who testified about the confessions and the re-enactment, and medical testimony regarding the wound and death. The accused presented alibis and testified (through records) to coercion and torture producing Alcantara’s confession, illiteracy making Alcantara unlikely to have understood the English-language confession, and that Exhibit "G" was p...(Subscriber-Only)
Issues:
- Were the extra-judicial confessions of Lauro Alcantara and Ricarte Obedoza admissible and of probative value against appellants Ambrocio Sumalbag and Londring Martinez?
- Was there sufficient evidence to sustain the convictions of Ambrocio Sumalbag and Londring Martinez for robbery in band with homicide ...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
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