G.R. No. L-4847 - People vs. Ansang

Case Summary (G.R. No. L-4847)

Factual Background

In October, 1949, Ansang complained to the Chief of Police of Maluso that Moros Berto was taking coconuts from Ansang’s plantation. The police chief directed Ansang to complain to the provincial fiscal, but Ansang was unable to see the officer. Despite this, Berto continued picking coconut fruits and claimed ownership of the plantation.

On October 7, 1949, Jubail, described as the foster son of Ansang, went to the seashore of Sangbay, Basilan City, Zamboanga. There he saw Moros Berto, Abdani, Eka, and Kasim loading seven sacks of copra gathered from the plantation. Jubail asked Berto what he was going to do with the copra. Berto replied that he would take it to the town of Isabela that same day, and Berto and his companions sailed toward that place.

Shortly afterwards, Moro Abdul Samad saw Jubail with Jaho boarding another vinta. Jubail carried three home-made bombs or hand grenades. When Moro Wahina asked what these objects were, Jubail answered that they were home-made bombs intended to be used for fishing. Jubail and Jaho later sailed away. When they returned to Sangbay, Samad and Wahina noticed that Jubail and Jaho no longer had the bombs and that they had not brought any fish.

From that time, Berto and his three companions have not been seen or heard from by anybody. Abdul Samad later saw pieces of Berto’s vinta on the seashore of the Island of Pilas. When authorities were apprised of the disappearance and discovery of wreckage, they began an investigation and arrested Ansang, Jubail, and Jaho.

The Confessions and the Charged Conduct

Ansang made a confession, marked Exhibit “B”, in which he stated that because Berto and his companions had taken away copra from his plantation, he ordered his foster son Jubail to follow them and kill them.

Jubail also made a written confession, stating that upon Ansang’s order he gathered three home-made bombs and invited Jaho to sail with him, telling Jaho that they were going to fish. With Jaho as helmsman, Jubail followed Berto’s vinta, which had sailed ahead. When they reached a point about seven brazas distant from Berto’s vinta, Jubail ignited the bombs one by one and threw them successively at Berto’s vinta, destroying it and causing the disappearance of the four passengers. After the attack, Jubail and Jaho sailed back and kept silent about what they had done.

Jaho likewise made a written confession. He said that Jubail invited him to go fishing with dynamite. Jaho acted as helmsman but, according to his confession, did not initially know that the purpose was to commit a serious crime. When they came near Berto’s vinta, Jaho noticed that Jubail was throwing bombs or hand grenades at the vinta. He told Jubail that had he known the purpose, he would not have accompanied him. Jaho explained that before going with Jubail he believed they were going fishing and had no idea at all that Jubail intended to commit a serious crime.

At trial, Ansang, Jubail, and Jaho did not assail the validity of their respective confessions. They confined themselves to a general denial of the crime charged. They did not claim that they had been forced, tortured, or induced by promises to make and sign the confessions.

Trial Court Disposition and Appeal

The Court of First Instance of Zamboanga acquitted Moro Jaho, but it convicted Ansang and Jubail. Each was sentenced to suffer reclusion perpetua, to pay the heirs of each victim jointly and severally an indemnity of P2,000, and to suffer the accessory penalties of the law. Each was likewise ordered to pay one-third of the costs. Ansang and Jubail appealed.

On appeal, appellants’ counsel argued that a conviction could not rest on an extrajudicial confession without proof of the corpus delicti, independent of the confession. The Court recognized the governing principle, but it held that the corpus delicti had been shown by facts established by evidence independent of the confessions.

The Parties’ Contentions on Corpus Delicti

Appellants contended that the prosecution failed to provide independent proof of the corpus delicti and sought to limit the evidentiary value of their extrajudicial confessions. The defense thus implied that, absent proof of the elements of the offense aside from the confessions, conviction could not legally stand.

The prosecution, as sustained by the reasoning of the decision, treated the independent evidence as sufficient to demonstrate that a specific crime had been committed and that Berto and his companions met a violent death as the result of criminal acts.

Independent Evidence Demonstrating Corpus Delicti

The Court found that several facts established by evidence independent of the confessions tended to establish the corpus delicti. It noted that Jubail was the foster son of Ansang, and that the prosecution evidence showed a grudge of Ansang against Berto arising from the coconut and copra-taking incidents. It also noted that Jubail and Jaho were seen by Samad and Wahina sailing from the shore of Sangbay, with Jubail carrying three hand grenades, and that when asked where they were going, Jubail answered that they were going to fish.

The Court emphasized that Berto and his companions never returned from the trip and were never seen or heard of afterward. It further observed that when Jubail and Jaho returned, they no longer had the hand grenades and did not bring any fish. It also considered that pieces of wreckage from Berto’s vinta were later seen on the shore of the Island of Pilas. From these circumstances, the Court concluded that Berto and his companions must have met a violent death due to the commission of a crime.

The Court’s Treatment of the Corpus Delicti Concept

To clarify the concept, the Court referred to U. S. vs. Valdez, (41 Phil., 497, 498). It quoted reasoning in that case to illustrate that the corpus delicti can be inferred from circumstances showing a violent end, even where the alleged victim was not directly shown dying in court. In Valdez, the Court considered how a threat with a knife and the immediate peril led to the deceased throwing himself into the river and disappearing, and it held that this sufficed to establish the corpus delicti because the conclusion of death was warranted.

The Court also invoked People vs. Marquez, [77 Phil., 93; 43 Off. Gaz., 1652, 1653], explaining that the term corpus delicti does not simply mean the “body of the crime” in a vulgar sense, such as the thing stolen in theft cases or a corpse or ruins in murder and arson. It held that, essentially, the term refers to proof that a specific crime was committed and that it consists of elements such as the occurrence of a certain result and criminal responsibility for that result. The Court likewise stressed that the rule on corpus delicti does not require proof, by independent evidence, of every element of the offense in the same manner as at trial; it only requires “some” evidence apart from the confession tending to show that a crime was committed.

Legal Basis and Reasoning for Affirmance with Modification

Apply

Case Syllabus (G.R. No. L-4847)

Parties and Procedural Posture

The People of the Philippines prosecuted Moros Ansang, Moro Jubail, and Moro Jaho for multiple murder before the Court of First Instance of Zamboanga.
Moro Jaho was acquitted, while Moros Ansang and Moro Jubail were convicted.
Moros Ansang and Moro Jubail appealed the judgment of conviction.
The appellate review resulted in an affirmance of guilt with a modification as to the indemnity and the imposition of costs.

Key Factual Allegations

In October 1949, Ansang complained to the Chief of Police of Maluso that Moro Berto was taking coconuts from Ansang’s plantation.
The chief of police advised Ansang to complain to the provincial fiscal, but Ansang was unable to see that officer.
Berto continued harvesting coconuts, asserting that he owned the plantation.
On October 7, 1949, Jubail, described as Ansang’s foster son, went to the seashore of Sangbay, Basilan City, Zamboanga, and saw Berto, Abdani, Eka, and Kasim loading seven sacks of copra from the plantation.
Jubail asked Berto about the copra, and Berto answered that he would bring it to Isabela that day.
Berto and his three companions sailed to Isabela and were later never seen or heard from again.
Afterward, Moro Abdul Samad observed Jubail with Jaho, boarding another vinta, with Jubail carrying three home made bombs or hand grenades.
Moro Wahina asked about the objects, and Jubail replied that they were home made bombs to be used for fishing.
When Jubail and Jaho returned to Sangbay, Samad and Wahina noticed that they no longer had the bombs and that they brought back no fish.
From that point, Berto, Abdani, Eka, and Kasim disappeared, and no subsequent sightings occurred.
Abdul Samad saw pieces of Berto’s vinta on the shore of the Island of Pilas.
When authorities learned of the disappearance and found wreckage, they investigated and arrested Ansang, Jubail, and Jaho.
Ansang made a confession stating he ordered Jubail to follow and kill Berto due to Berto’s taking of copra.
Jubail made a written confession stating that upon Ansang’s order he gathered three home made bombs and invited Jaho to sail by telling him they were going to fish.
According to Jubail’s confession, with Jaho as helmsman, they followed Berto’s vinta, ignited the bombs one by one, and threw them at Berto’s vinta, destroying it and causing the disappearance of Berto and his passengers.
Jaho also made a written confession stating he was invited by Jubail to go fishing with dynamite, served as helmsman, and only discovered that bombs were being thrown after they neared Berto’s vinta.
Jaho’s confession stated that if he had known the true purpose, he would not have accompanied Jubail, and that he had believed they were going fishing.

Confessions and the Corpus Delicti Requirement

At trial, Ansang, Jubail, and Jaho did not assail the validity of their confessions and confined themselves to a general denial