G.R. No. 133858 - People vs. Satorre

Herminiano Satorre alias Emiano Satorre was charged with murder via an information stating that on or about May 25, 1997, at approximately 2:00 a.m., in Sitio Kamari, Barangay Calidngan, Municipality of Carcar, Cebu, he willfully, unlawfully, and feloniously shot Romero Pantilgan in the head with a .38 caliber paltik revolver, with evident premeditation and by means of treachery, causing instantaneous death.
Upon arraignment, appellant pleaded "not guilty."

Gliceria Saraum, wife of the victim, testified that she was asleep with her children and her mother at their house in Tagaytay, Carcar; the victim had gone out to attend a fiesta. She was awakened by a gunshot and found her husband dead on the porch with a gunshot wound to the head.
Rufino Abayata, barangay kagawad, recounted that around 7:00 a.m., he and another kagawad, Pio Alvarado, went to verify a report of a dead body on the Saraum porch. Abraham Satorre, appellant’s father, told them appellant was the shooter. Efforts to find appellant at his brother Felix’s house were futile as appellant had left. Subsequently, appellant’s brothers Margarito and Rosalio surrendered the alleged murder weapon to the police via Rufino.
Flavio Gelle testified that he accompanied Abraham and appellant to Barangay Captain Cynthia Castañares’s residence where appellant admitted killing Pantilgan.
Barangay Captain Cynthia Castañares testified that appellant confessed to killing Pantilgan because he was struck with a piece of wood by the victim. Later, at the Carcar Police Station, appellant allegedly recounted that he killed Pantilgan with a gun wrested from the latter. She executed a sworn affidavit to this effect.
Dr. Plebia Villanueva, Municipal Health Officer, certified that the cause of death was a gunshot wound.
Bonifacio Ayag, an NBI ballistics expert, identified the spent bullet from the victim’s head wound as fired from the firearm surrendered by appellant’s brothers.

Appellant denied the charges, claiming he was asleep at home during the incident.
He alleged Rufino Abayata bore him a grudge for tying the latter’s cow to prevent it from eating corn on his farm.
Appellant denied making any confession, ownership of the paltik .38 revolver, or surrendering a firearm to Captain Castañares.
Abraham Satorre and brothers Rosalio and Felix corroborated appellant’s denial of surrendering any gun or admitting guilt.

The Regional Trial Court, Branch 18 of Cebu City, found the prosecution’s evidence credible and convicted appellant of murder.
Sentence imposed was reclusion perpetua with accessory penalties; indemnity of ₱50,000.00 to the victim’s heirs and payment of costs.
Appellant was credited with full detention, conditioned on compliance with penitentiary rules.

Specifically, appellant argued the alleged confession—central to prosecution’s case—was hearsay, inadmissible, not reduced to writing, and made without counsel.

Whether the trial court erred in admitting and giving full credence to appellant’s alleged oral extrajudicial confession made before the Barangay Captain and barangay kagawads.

Whether the prosecution established appellant’s guilt beyond reasonable doubt, considering the circumstances of the confession and corroborative evidence.

Whether the conviction was proper considering appellant’s constitutional right against self-incrimination and the procedural safeguards requiring voluntariness of confession.