Case Digest (G.R. No. L-22160)
Facts:
The People of the Philippines v. Teodoro Tamani, G.R. Nos. L-22160 and L-22161, January 21, 1974, the Supreme Court Second Division, Aquino, J., writing for the Court. The accused-appellant is Teodoro Tamani; the criminal actions were prosecuted by the People of the Philippines as plaintiff-appellee. At the trial level (Court of First Instance of Isabela, Judge Pedro C. Quinto), Tamani was convicted of the murder of Jose Siyang and the attempted murder of Mayor Eduardo Domingo. The trial court sentenced him to "life imprisonment" (later treated as reclusion perpetua) and ordered indemnities of P6,000 for the heirs of Siyang and P2,000 for Domingo; it also imposed an indeterminate term for the attempted murder conviction.The trial court's decision was promulgated on February 14, 1963; a copy was served on defendant's counsel on February 25, 1963. Tamani filed a motion for reconsideration on March 1, 1963 which was denied; the order of denial was served by registered mail on July 13, 1963 on counsel through his wife. Tamani filed his notice of appeal on September 10, 1963. After briefs were filed, the Solicitor General moved to dismiss the appeal as late; the motion was deferred for consideration on the merits, but was renewed in appellee's brief.
On the merits, the prosecution relied on extrajudicial confessions signed and thumbmarked by Tamani on October 2 and 3, 1956 before NBI agents (Exhs. A and B), the autopsy certificate showing four through-and-through fatal gunshot wounds on Siyang, the testimony of eyewitnesses (notably Mrs. Juana Vittori de Ibarra and her daughter), NBI agents' testimony about investigation and confrontation, and physical evidence (empty shells). The defense repudiated the confessions as involuntary (alleging torture and maltreatment while in custody) and asserted an alibi supported chiefly by testimony of Francisco Siyang (father of the deceased) that policemen Gaspar Ibarra and Melchor Tumaneng fired the fatal shots.
The trial court found the corpus delicti proven, held that the extrajudicial confession was corroborated by corpus delicti and attendant details, discredited Tamani's alibi and Francisco Siyang's inconsistent testimony, and accepted the eyewitness identification by Mrs. Ibarra. The court concluded the killing of Jose Siyang was murder qualified by treachery and that the shooting of Mayor Domingo constituted attempted murder; it rejected the contention tha...(Pro-only)
Issues:
- Should the appeal be dismissed as tardily filed under Rule 122, Sec. 6 of the Rules of Court?
- Was Tamani's extrajudicial confession voluntary and sufficiently corroborated by corpus delicti to support conviction?
- Did the trial court err in rejecting Tamani's alibi and the testimony of Francisco Siyang so as to create reasonable doubt?
- Were the crimes committed murder (with treachery) and attempted murder rather than a complex crim...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)