Case Digest (G.R. No. L-62593)
Facts:
The People of the Philippines v. Augusto Pizarro and Boy Mamuri, G.R. No. L-62593, August 31, 1984, Supreme Court First Division, Relova, J., writing for the Court. The plaintiff-appellee is The People of the Philippines; the accused-appellant is Augusto Pizarro (one co-accused, Boy/Ramon Mamuri, remained at large; a third, Sofronio Villanueva, died before information was filed).On June 15, 1980 at about 2:00 p.m., Rogelio Sabalboro heard a gunshot from his brother Cornelio’s house in Talahib, Lumbang, Laguna. Rogelio went toward Cornelio’s house and encountered three men coming from that house, one of whom he identified as Augusto Pizarro; one of the trio warned him not to report the incident to the police or he and his family would be killed. The three went toward a forested area. Rogelio returned home, informed his mother, and later reported the incident to the barangay captain; the body of Cornelio was recovered and brought to the poblacion.
Dr. Rogelio Javan, Municipal Health Officer, performed an autopsy and produced a necropsy report (Exhibit “A”) showing death from massive hemorrhage and brain damage secondary to gunshot wounds of the head. PC Sgt. Laureano Luzaran investigated and identified a written statement by appellant (Exhibit “E”) thumbprinted before the Assistant Fiscal; in that statement Pizarro admitted participation, said Sofronio Villanueva fired the gun at Cornelio’s head, that Pizarro acted as an “alalay,” and that they were paid P400 (P50 to Pizarro).
At trial the prosecution presented testimony of Rogelio Sabalboro, Dr. Javan, and PC Sgt. Luzaran and offered the necropsy and the written statement. The defense waived presentation of evidence and filed a memorandum instead. On September 30, 1982 the trial court convicted Augusto Pizarro of murder and sentenced him to reclusion perpetua, ordered indemnity of P12,000, and credited him with his detention period; the conviction was appealed to the Supreme Court First Division. The information against one co-accused was provisionally dismissed on July 14, 1981; Sofronio Villanueva had died before informa...(Pro-only)
Issues:
- Was Exhibit “E,” the accused’s extra-judicial written statement, admissible in evidence given the protections of Section 20, Article IV of the 1973 Constitution?
- Did the prosecution prove the corpus delicti and appellant’s guilt beyond reasonable doubt so as to justify co...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)