Facts:

On June 22, 1972, at approximately 10:00 AM, Ernesto Maderse was shot and killed while walking along the Suage riverbank in Barrio Barasalon, Janiuay, Iloilo City. His body was discovered and transported to Janiuay the same day. The following day, Dr. Asisclo Tirador, the Rural Health Physician, conducted a post-mortem examination and found that Maderse had sustained eight gunshot wounds. Two weeks later, on July 6, 1972, Wilfredo Talla, along with his siblings and sister-in-law, was summoned by police for questioning regarding the murder. On that same day, Wilfredo executed a written extrajudicial confession, admitting to the killing and implicating his relatives. Subsequently, both Wilfredo and his brother Jolito were charged with murder. During their arraignment, they pleaded not guilty. The prosecution presented two eyewitnesses, Anacleto Molina and Felipe Marbebe, who testified that they witnessed Jolito shoot Ernesto with a homemade shotgun, known locally as "pugak...

Facts:

1. Incident Overview: On June 22, 1972, Ernesto Maderse was shot and killed with a homemade shotgun (pugakhang) while walking along the Suage riverbank in Barrio Barasalon, Janiuay, Iloilo City. His body was brought to Janiuay on the same day.
2. Post-Mortem Examination: Dr. Asisclo Tirador conducted a post-mortem examination on June 23, 1972, revealing that Ernesto suffered eight gunshot wounds.
3. Investigation and Confession: On July 6, 1972, Wilfredo Talla and his siblings were summoned by police for investigation. Wilfredo executed a written extrajudicial confession admitting to the killing and implicating his brothers and sister-in-law.
4. Charges Filed: Wilfredo and Jolito Talla were charged with murder. The information alleged that they conspired to kill Ernesto with treachery and evident premeditation.
5. Trial Proceedings: During the trial, the prosecution presented two eyewitnesses, Anacleto Molina and Felipe Marbebe, who testified that they saw Wilfredo and Jolito at the scene of the crime. Wilfredo and Jolito pleaded not guilty and interposed the defense of alibi.
6. Defense Testimonies: The defense presented witnesses, including Jolito Talla, who claimed to be elsewhere during the incident, and Wilfredo Talla, who alleged that his confession was obtained through force and intimidation.
7. Trial Court Decision: The trial court convicted Wilfredo Talla of murder and sentenced him to reclusion perpetua, while acquitting Jolito Talla. Wilfredo appealed the decision.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntariness of Confession: A confession is presumed voluntary unless proven otherwise. Wilfredo Talla failed to provide sufficient evidence to rebut this presumption.
2. Conspiracy Liability: A person may be held liable for the criminal act of another if there is conspiracy or unity of purpose. Wilfredo Talla's actions demonstrated his participation in the conspiracy to kill Ernesto Maderse.
3. Credibility of Witnesses: Minor inconsistencies in witness testimonies do not necessarily discredit their credibility. Such inconsistencies may even indicate that the testimonies were not rehearsed.
4. Defense of Alibi: Alibi is a weak defense, especially when the accused is positively identified by credible witnesses.
5. Qualifying Circumstances: Treachery and evident premeditation were present in the killing, as the assailants hid behind a rock and waited for the victim, ensuring the crime's execution without risk to themselves.