G.R. No. L-30577 - People vs. Obedoza

On the night of May 28, 1967, in Barrio Salagusog, Cuyapo, Nueva Ecija, several armed persons invaded the residence of Maximiniano Cabangcala, where he, his wife Isabel Dacanay, and their two grandchildren were present.
The perpetrators stole four carabaos (three males and one female) and one cow, which were covered by certificates of ownership, and in the process, gunfire was discharged.
Maximiniano Cabangcala sustained injuries after jumping out of the window upon hearing the shots; he was hit by pellets from a .12 gauge shotgun, as later confirmed by Dr. Pio Alberto.
The pellet wounds, measuring approximately six inches in diameter, led to gangrene when the victim refused an advised leg amputation; consequently, Cabangcala died on June 13, 1967.

Initially, the immediate identification of the culprits was not possible. It was only on October 24, 1967, that the police investigation yielded a confession from Lauro Alcantara, who then identified his companions in the crime.
Alcantara’s confession implicated several persons, including Ben Bocasas (accused of firing the shot), Quines Linda (supposedly involved in the sale of the stolen animals), and Ambrocio Sumalbag (the informer on the whereabouts of the cattle).
Ricarte Obedoza was also implicated; he allegedly confessed that he was present when Ben Bocasas shot Cabangcala under orders from Sumalbag.

Based on the investigation, a complaint for "Robbery in Band with Homicide" was filed on November 22, 1967, in the Municipal Court of Cuyapo. An amendment on November 27, 1967, included Quines Linda as an accused.
The case was subsequently forwarded to the Court of First Instance of Nueva Ecija, Branch IV, at Guimba, and the Provincial Fiscal submitted the corresponding information on March 18, 1968, which detailed the alleged conspiracy and execution of the crime.

Of the accused, only Lauro Alcantara, Ambrocio Sumalbag, and Londring Martinez were arraigned and tried, while others remained at large.
Evidence hinged on extra-judicial confessions provided by Alcantara and Obedoza—confessions that were later reduced to writing and sworn before a Municipal Judge.
The prosecution also presented physical evidence, including certified ownership documents of the stolen cattle and exhibits labeled "B" through "H," notably Exhibit "G," a crime scene sketch.
Key prosecution witnesses testified on various matters, including the sequence of events during the robbery, the victim’s injuries, and the police investigation.

Lauro Alcantara claimed he was in Barrio San Vicente, Rosales, Pangasinan, and portrayed his arrest and subsequent maltreatment as coercive and leading to a false confession.
Londring Martinez asserted that he was at Sto. Tomas, Pangasinan, with his family, having no relation to the events at Barrio Salagusog.
Ambrocio Sumalbag explained his involvement merely as aiding in the recovery of stolen animals, a role influenced by his position as a barrio councilor and confidential agent of the governor, not as an accomplice in the robbery.

The defense also questioned the credibility and voluntariness of the extra-judicial confessions, highlighting that the accused were subjected to threats, coercion, and questioned in a language or setting that they could not fully understand.

Whether the extra-judicial confessions of Lauro Alcantara and Ricarte Obedoza, which were obtained under alleged coercion and threats, can be considered voluntary and credible evidence against the accused.
Whether the failure of counsel to cross-examine the central police witnesses on the substance and conditions surrounding these confessions affected their probative value.

Whether the remaining evidence, primarily the extra-judicial confessions and police accounts (including Exhibit "G"), sufficiently established the direct participation of Ambrocio Sumalbag and Londring Martinez in the commission of robbery in band with homicide.
Whether the inherent inconsistencies and hearsay nature of the confessions (especially as they were not corroborated by independent evidence) met the standard of proof beyond reasonable doubt.

Whether the trial court erred in not properly reconciling the defense’s objections regarding the admissibility of the extra-judicial confessions.
How the use of physical evidence, such as the re-enactment sketch prepared by Police Sgt. Rufino de Gracia, impacted the overall integrity of the prosecution’s case, given the absence of corroboration from the accused.