Title
People vs. Tena
Case
G.R. No. 100909
Decision Date
Oct 21, 1992
An 82-year-old man was killed in a robbery; a co-accused's extrajudicial confession implicated Solito Tena, but the Supreme Court acquitted him, ruling the confession inadmissible under *res inter alios acta* due to lack of independent evidence.

Case Digest (G.R. No. 191015)

Facts:

  • Incident and Victim
    • On June 19, 1988, Alfredo Altamarino, Sr., 82 years old, was found dead inside his bedroom in Mauban, Quezon.
    • The body was arranged orderly on the bed. He sustained eight stab wounds (two on the neck, six on the chest), a depressed fracture on the right side of the head, and a lacerated wound on his right eyebrow.
    • Dr. Victorino Q. Arana conducted a post-mortem examination and declared cardiac tamponade as the cause of death.
  • Evidence of Robbery
    • The victim’s bedroom was in disorder, with ransacked drawers.
    • Missing items included a diamond ring worth P20,000; a Rolex watch worth P8,000; a Seiko watch costing P3,000; a tie clip with 18 diamonds worth P50,000; two men’s rings valued at P25,000; cash amounting to about P7,000 to P8,000; and some dollars.
  • Initial Investigation
    • Suspicion initially fell on the deceased’s caretakers, William Verzo and Ofelia Ritual; however, police investigation found no evidence against them.
    • The eldest child of the deceased, Emma Altamarino Ibana, sought the help of the National Bureau of Investigation (NBI).
  • NBI Investigation and Arrest
    • On January 11, 1989, NBI agents Reynaldo Manzanero and Celso Ginga arrived in Mauban to investigate.
    • The Mauban Police reported suspicion moving towards a syndicate operating in Lucena City involved in a related robbery at a Petron Gas Station.
    • An individual named Adelberto Camota, a member of the syndicate, was in detention. The agents interrogated him.
    • A polygraph examination was conducted on Camota on February 1, 1989, with his alleged consent.
    • Upon confronting Camota with polygraph results, he executed an extra-judicial confession admitting participation in the robbery-killing and identified Solito Tena, Virgilio Conde, Jose de Jesus, and an unidentified person as accomplices.
  • Charges and Trial
    • An information was filed against Virgilio Conde, Jose de Jesus Jr., Adelberto Camota, Solito Tena, and John Doe for robbery with homicide.
    • Virgilio Conde and Solito Tena pleaded not guilty on November 12, 1989; Camota also pleaded not guilty when arraigned on January 17, 1990.
    • Jose de Jesus and John Doe were not apprehended. Virgilio Conde escaped detention and was tried in absentia.
    • The trial court convicted Virgilio Conde, Adelberto Camota, and Solito Tena, sentencing them to reclusion perpetua (initially stated as 20 years, amended to 30 years) and ordered joint and several indemnity payment of P120,000 to the victim’s heirs.
  • Appeal of Solito Tena
    • Solito Tena appealed his conviction on the basis that the extrajudicial confession of Camota was inadmissible against him.
    • The trial court had found the confession admissible, ruling that Camota’s constitutional rights were respected and that there was no coercion in the confession.
    • The conviction largely rest on the confession, as there were no eyewitnesses to the crime and circumstantial evidence did not definitively link Tena to the crime.
    • Camota later repudiated his extra-judicial confession in court, denying knowledge of the crime and of Solito Tena.

Issues:

  • Whether or not the extrajudicial confession of Adelberto Camota is admissible and can be used as evidence against co-accused Solito Tena.
  • Whether the conviction of Solito Tena can be sustained where the main evidence against him was the confession of a co-accused who has denied the truth of his statement in court.
  • Whether the correction of the penalty of reclusion perpetua from twenty (20) years to thirty (30) years by the trial court was proper and lawful.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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