G.R. No. L-31653 - People vs. Ortilla y Panganiban

On the evening of July 22, 1969, at about 11:00 p.m., a hand grenade exploded at the Thomas Jefferson Memorial Library located on Magsaysay Boulevard, Sta. Mesa, Manila.
The explosion caused a crater on the pavement; the victim, Rodolfo Carlos y Salazar, was found prostrate on the ground and later pronounced dead due to “shock and hemorrhage due to multiple shrapnel wounds” on various parts of his body.
Initial evidence included exhibits (B, B-1, and D) detailing the physical damage and the victim’s injuries.

Accused Renato Ortilla y Panganiban was picked up by Manila Police Department operatives at his residence (3181 Mariano Street, Sta. Mesa) following the explosion for questioning.
During his first interrogation at the MPD headquarters on Isaac Peral Street, Ortilla denied involvement in the grenade-throwing incident, attributing his black eye to a mauling incident on July 20, 1969 by Ladislao Garcia, Rolando Reyes, and Bentot.
A key witness, Detective Wenceslao Sunga—a neighbor of the accused—vouched for him and ensured his availability for subsequent proceedings, leading to Ortilla’s initial release.

On July 26, 1969, Ortilla was again apprehended by police, who were convinced of his involvement in the grenade incident.
During the subsequent interrogation, Ortilla executed multiple statements:

A two-page handwritten confession (Exhibit G) admitting to throwing the grenade.
Two annexed handwritten sketches:

All these statements were sworn before Manila Assistant City Fiscal Ricardo Conjares and witnessed by a lawyer and a stenographer, establishing the documentary basis of the confession.

Ortilla later claimed that his confessions were not voluntary but the result of police coercion, intimidation, and physical abuse during interrogation.

He testified that during his recapture on July 26, 1969, he was blindfolded, struck repeatedly (including being stamped, kicked, and struck on various parts of his body), and even forced to lie down while water was poured on his face and nostrils.
Additional abuse described included having someone “ride on his stomach.”

A corroborative medical examination by Dr. Mariano Lara (Exhibit 2) recorded injuries on Ortilla’s arms, wrists, chest, and neck, which the doctor noted were approximately four days old, consistent with the alleged maltreatment timeline.
The physical evidence of injuries and the conflicting accounts regarding police conduct became central to the factual disputes.

Accounts from various witnesses including a police reporter and patrolmen who testified that the statements were executed in a voluntary manner.
A reenactment of the grenade incident conducted on July 26, 1969, at the crime scene, which recreated the accused’s alleged actions.

The prosecution relied solely on the extra-judicial confessions, given the absence of eyewitness testimony directly linking Ortilla to the grenade throwing.

An information for murder (Criminal Case No. CCC-V-1345) was filed, charging Ortilla with murder qualified by the use of an explosive, with aggravating circumstances of treachery.
The trial court (Circuit Criminal Court of Manila) found Ortilla guilty beyond reasonable doubt as principal in the crime, sentencing him to death and awarding various damages to the victim’s heirs.
Ortilla, however, appealed his conviction, basing his appeal on the claim of insufficiency of evidence and the involuntariness of his confessions.

Whether the extra-judicial confessions (Exhibits G, G-1, G-2, and H) were obtained voluntarily or were the result of coercion and physical abuse.
Whether the alleged maltreatment and physical injuries sufficiently negate the credibility and admissibility of the confessions.

Whether there exists any direct testimonial or objective evidence linking Ortilla to the act of throwing the grenade, independent of his confession.
The reliability of circumstantial evidence presented by the prosecution in the absence of an eyewitness identification.

The consistency and credibility of the rebuttal testimonies from police officers, including Assistant City Fiscal Conjares and Patrolman Gorospe.
Whether the absence of any complaint by Ortilla regarding police abuse at the time undermines his claims of coercion.

The evidentiary value and implications of the public reenactment of the crime.
How the detailed nature of Ortilla’s statements, including minute observations not known to the police, affects the determination of voluntariness.