Title
People vs. Ruperto Metran
Case
G. R. No. L-4205
Decision Date
Jul 27, 1970
Ruperto Metran was convicted of murder and sentenced to reclusion perpetua for his involvement in the kidnapping and killing of Valentina Tanala, with the court affirming the conviction based on evidence of conspiracy and his confession, despite his claims of coercion and alibi.
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Case Digest (G. R. No. L-4205)

Facts:

  • The appellant, Ruperto Metran, was convicted of murder by the Court of First Instance of Leyte and sentenced to reclusion perpetua.
  • The incident occurred on February 26, 1948, in Hiagsam, Jaro, Leyte.
  • Valentina Tanala, her sister Potenciana Tanala, and her niece Constancia Tanala were awakened by five armed men, including the appellant, who demanded entry into their house.
  • The intruders ransacked the house searching for pistols.
  • Two men dragged Constancia away, while three men, including the appellant, took Valentina about thirty meters away.
  • Constancia returned to the house after being released, and three gunshots were heard shortly thereafter.
  • Valentina's body was found the next morning near Porfiria Basitio's house.
  • Dr. Martin Reyes confirmed Valentina died from multiple gunshot wounds.
  • The appellant signed an affidavit admitting involvement but claimed he did not remember who shot Valentina.
  • Prosecution witnesses, including Potenciana, Constancia Tanala, and Cornelio Samson, testified against the appellant.
  • The appellant's defense claimed he was forced to associate with the gang out of fear and was in Ormoc, Leyte, during the crime. He also claimed his confession was coerced.
  • The trial court found the defenses unconvincing and convicted him of murder.

Issue:

  • (Unlock)

Ruling:

  1. The court ruled that the appellant's confession was not involuntarily given.
  2. The court affirmed the conviction of the appellant for murder.
  3. The court did not consider the aggravating circumstances...(Unlock)

Ratio:

  1. The court found the appellant's claim that his confession was coerced to be an afterthought. He did not specify the kind of torture or pressure that led him to confess and did not complain to the justice of the peace about any pressure from the investigating officer. Additionally, the appellant's affidavit contained details that matched the known facts of the case, lending credibility to the confession.
  2. The court held that conspiracy was sufficiently established. The appellant was shown to be a member of the gang that kidnapped and killed Valentina Tanala. His presence and participation in the events leading to Valentina's death, coupled with the gunshots heard ...continue reading

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