Facts:

The case revolves around the murder of 82-year-old Alfredo Altamarino, Sr., whose lifeless body was discovered on June 19, 1988, at his residence located at the corner of Gardner and Regidor Streets in Barangay Sadsaran, Mauban, Quezon. The victim, identified with severe injuries, bore eight stab wounds, two in the neck and six in the chest, alongside a depressed skull fracture and a lacerated eyebrow. The post-mortem examination conducted by Dr. Victorino Q. Arana determined cardiac tamponade as the cause of death.

Upon investigation, the crime scene revealed signs of a violent struggle and theft; the victim's personal effects, including jewelry and cash valued at over P100,000, were missing. Initially, suspicion fell upon the caretakers of the deceased, William Verzo and Ofelia Ritual, but the investigation by the local police yielded no substantial evidence against them. Subsequently, Emma Altamarino Ibana, the victim's daughter, sought assistance from the National Bu

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Facts:

Incident and Discovery of the Crime

• On June 19, 1988, 82-year-old Alfredo Altamarino, Sr. was found dead in his bedroom at his residence in Barangay Sadsaran, Mauban, Quezon.
• The victim’s body had eight stab wounds (two in the neck and six in the chest), a depressed fracture on the right portion of his head, and a laceration on his right eyebrow.
• The post-mortem examination, conducted by Dr. Victorino Q. Arana, revealed that cardiac tamponade was the immediate cause of death.

Crime Scene and Initial Investigation

• The bedroom was discovered in disarray, with opened and ransacked cabinet drawers.
• Items reported missing included valuable jewelry (a diamond ring, a tie clip with diamonds, men’s rings), watches (Rolex and Seiko), cash amounting to approximately P7,000–P8,000, and an undetermined sum in dollars.
• Initial suspicion fell on the deceased’s caretakers, William Verzo and Ofelia Ritual, but an investigation by the Mauban Police Force did not produce sufficient evidence for charges.

Participation of the National Bureau of Investigation (NBI)

• Emma Altamarino Ibana, the eldest child of the victim, sought assistance from the NBI.
• On January 11, 1989, NBI Agents Reynaldo Manzanero and Celso Ginga commenced their own investigation in Mauban.
• The shift in suspicion pointed toward a syndicate operating in Lucena City and nearby areas, particularly linked to the robbery of a Petron Gas Station.

Extrajudicial Confession and Polygraph Examination

• Among the suspects was Adelberto Camota, already detained, who was interrogated by the NBI.
• Sensing that Camota might be withholding information, the agents requested a polygraph examination which was carried out on February 1, 1989, by Polygraph Examiner II Ernesto A. Lucena.
• Shortly after, Camota executed an extra-judicial confession in the presence of Atty. Albert Siquijor, admitting his participation in the robbery-killing of Alfredo Altamarino, Sr.
• Camota’s confession implicated several individuals, naming Virgilio Conde, Jose de Jesus, Solito Tena, and an unidentified person as his accomplices.

Filing of Charges and Trial Court Proceedings

• An information was filed against Virgilio Conde, Jose de Jesus Jr., Adelberto Camota, Solito Tena, and a John Doe for robbery with homicide.
• Upon arraignment, Virgilio Conde, Solito Tena, and Adelberto Camota pleaded not guilty; later, Virgilio Conde escaped from detention and was tried in absentia.
• The Trial Court rendered a decision on February 26, 1991, finding Conde, Camota, and Tena guilty beyond reasonable doubt of the complex crime of robbery with homicide.
• Initially, the accused were sentenced to TWENTY (20) YEARS of reclusion perpetua along with an indemnity/damages payment; an amended judgment on April 10, 1991, changed the sentence to THIRTY (30) years of reclusion perpetua.

Evidence and Basis of Conviction

• The conviction was based chiefly on the extrajudicial confession of Adelberto Camota.
• Despite Camota’s later repudiation of his confession in open court, the Trial Court found it admissible after determining that:
• Camota’s constitutional rights (to remain silent and to counsel) were observed and protected.
• There was no evidence of force, coercion, or maltreatment during the confession’s execution.
• The details in the confession were consistent with the established facts (time, date, and crime scene details).
• The circumstantial evidence, such as the number and nature of the wounds and the flight of one suspect (Virgilio Conde), further supported the conviction.

Impact on Accused-Appellant Solito Tena

• Solito Tena centered his appeal on the propriety of admitting Camota’s extrajudicial confession as evidence against him.
• The principle of res inter alios acta alteri nocere (things done between strangers ought not to injure those who are not parties to them) and the related provisions of the Rules of Court (Sections 28 and 30, formerly Sections 25 and 27) became central to the appeal.
• The Court’s examination included a detailed inquiry into whether the confession should be used against a co-accused when independent evidence of Tena’s complicity was lacking.

Issue:

Admissibility and Extensibility of the Extrajudicial Confession

• Whether the extrajudicial confession of Adelberto Camota, even if admitted as evidence against him, could be legally extended against other co-accused, specifically Solito Tena, under the maxim res inter alios acta alteri nocere.
• Whether the confession violated Camota’s constitutional rights or whether its admission violated the principle of self-incrimination by binding a party not responsible for the act.

Sufficiency of Independent Evidence Against Solito Tena

• Whether there existed any independent evidence, apart from Camota’s confession, linking accused-appellant Tena to the commission of the crime.
• Whether the circumstantial proofs (such as the state of the crime scene and the victim’s wounds) could, independently, sustain a conviction against Tena.

Appropriateness of the Trial Court’s Sentencing Amendment

• Whether the Trial Court erred in specifying a fixed duration (twenty or thirty years) for reclusion perpetua, considering that such penalties have their duration interpreted in line with Articles 27 and 70 of the Revised Penal Code.
• Whether this imputation affected the fairness or constitutionality of the imposed sentence.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)