G.R. No. L-18546 - People vs. Opiniano

The case involves the People of the Philippines versus Prudencio Opiniano and several co-accused.
The accused were members of a religious organization called Filipinasnon Kabus Magu-uma, founded in 1954 by Florencio Bautista, with Prudencio Opiniano as the supreme leader.
The organization’s membership largely consisted of uneducated and gullible individuals who accepted the leader’s words as gospel, thereby cultivating a fanatical and cult-like adherence.

About two weeks prior to March 25, 1960, a number of accused, including Opiniano, Bautista, and others, stayed at the house of Cosme Mabuang in Matag-ub, Leyte.
On the morning of March 25, 1960, a meeting was convoked at the Mabuang residence where all present were exhorted by Opiniano and Bautista to challenge the Philippine Constabulary (PC) soldiers.
The leaders informed the members that the PC soldiers were allegedly hired by a priest with a reward of P70,000.00 to kill Opiniano.
A signal for the attack was established through the raising of Opiniano’s cane to his right shoulder.

After the meeting, Opiniano and his followers proceeded to barrio Sombalawan, with prior knowledge that PC soldiers were in barrio Santo Rosario to execute a warrant for the arrest of Opiniano, Bautista, and Maria Lagbas related to an estafa case.
The PC soldiers, led by Pfc. Remy Parambita and Pfc. Luis Meroy (with the aid of two civilians), identified themselves and showed a copy of the arrest warrant.
Upon being informed of their arrest, Opiniano and his group, armed with bolos, daggers, and canes, refused to surrender and instead challenged the soldiers.
Following the signal (the cane raised), the accused and their followers surrounded the soldiers and attacked them, culminating in a violent clash.

The assault resulted in severe injuries: PC Pfc. Luis Meroy sustained multiple stab, incised, and puncture wounds and later died from shock secondary to hemorrhage; Pfc. Remy Parambita was wounded with injuries estimated to require 60 to 120 days of healing.
Multiple assailants were identified by the evidence, including direct participation by Opiniano, Bautista, and others during the assault against the PC soldiers.
After the attack, the soldiers were forced to retreat due to the overwhelming number of assailants, and the injured were attended to under chaotic circumstances.

The immediate aftermath saw the arrest of the accused, who were eventually tried in the Court of First Instance of Leyte.
Some accused later withdrew their appeals, while the Court dealt primarily with the appeals of Prudencio Opiniano, Florencio Bautista, Leonardo Cabalican, Drillo Panoy, and Bartolome Caiwan.
Each accused executed a written, extrajudicial confession in which they detailed their roles in the assault. These confessions included both inculpatory and, at times, exculpatory statements.
Testimonies from victims, witnesses, and the accused themselves provided intricate details of the sequence of events, weapons used (bolos, canes, daggers), and the method of the assault.
There were also claims of maltreatment while in custody and during the preparation of the confessions, though these claims were found to be inconsistent among the accused’s testimonies.

The religious organization not only functioned as a benevolent society (having secured a license and certification) but also engaged in activities that included unbridled solicitation of contributions, which later led to a criminal complaint for estafa against Opiniano, Lagbas, and Bautista.
The indoctrination and moral influence of Opiniano over his followers played a significant role in inciting them to defy lawful orders, contributing to the violent encounter.
The trial record demonstrated that despite the calculated steps taken by the accused to evade arrest for the estafa case, they ultimately engaged in an armed confrontation with state agents based on the instructions and beliefs instilled by their leaders.

Whether the trial court erred in determining that a meeting took place on March 25, 1960, during which the accused planned the murder of PC soldiers, based on the evidence presented.

Whether the admission of the extrajudicial confessions—despite claims of coercion and maltreatment—violated due process by compromising the voluntariness and reliability of the evidence.

Whether the factual findings, even without relying on the extrajudicial confessions, were sufficient to support the conviction of the accused given the inconsistencies and contradictory testimonies regarding the assault and alleged maltreatment.

Whether the composite of circumstantial evidence, extrajudicial confessions, and corroborative testimonies conclusively established the guilt of the accused beyond reasonable doubt.