Case Digest (G.R. No. L-35284)
Facts:
People of the Philippines v. Ramon Roa, Juanito Sagayon, alias "Lala", Simeon Ayumon, Resurreccion Villanueva alias "Rete", and Serafin Catayoc, G.R. No. L-35284, January 17, 1975, Supreme Court Second Division, Fernando, J., writing for the Court. The prosecution charged several respondents with the murder of Baltazar Varquez (brother of then-mayor Manuel Varquez) allegedly committed on November 7, 1971 in Balingasag, Misamis Oriental.The first information (Nov. 17, 1971) named Benedicto Borres, Serafin Catayoc and two John/Peter Does; an amended information followed Nov. 23, 1971. Appellants Ramon Roa, Juanito Sagayon (alias “Lala”) and Resurreccion Villanueva (alias “Rete”) were not added until the second amended information filed Dec. 11, 1971; a third amended information was filed Dec. 16, 1971. Arraignment occurred Dec. 24, 1971 when Sagayon entered a plea of guilty and thereafter testified for the prosecution. Subsequent trial hearings were held on Dec. 31, 1971; Jan. 15, 1972; Jan. 31, 1972; and March 30, 1972, producing a voluminous transcript and numerous witnesses, including police officers and medical personnel.
The trial court (Circuit Judge Meynardo A. Tiro) found a conspiracy instigated by Roa, principally relied upon the testimony and extrajudicial confessions of Sagayon, and described how Sagayon allegedly shot Varquez at close range with a 12-gauge shotgun. The trial judge convicted Roa, Sagayon and Villanueva (decision rendered June 21, 1972). One accused, Serafin Catayoc, secured dismissal for insufficiency of evidence; Simeon Ayumon remained at large.
On appeal to the Supreme Court, appellants challenged the sufficiency and voluntariness of Sagayon’s confessions and testimony, the improvidence of his guilty plea, the alleged lack of corroboration for the conspiracy charge against Roa and Villanueva, and other evidentiary i...(Subscriber-Only)
Issues:
- Was the conviction of the appellants properly sustained where the prosecution’s case rested mainly on the testimony and extrajudicial confessions of Juanito Sagayon who later recanted and alleged coercion?
- Was the conviction of Ramon Roa and Resurreccion Villanueva sufficiently established beyond reasonable doubt given the lack of independent corroboration and the initial naming of another suspect (Benedicto Borres)?
- Was Sagayon’s December 24, 1971 plea of guilty improvidently ent...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)