Title
People vs. Baharan
Case
G.R. No. 188314
Decision Date
Jan 10, 2011
On 14 February 2005, an Abu Sayyaf-linked bus bombing in Manila killed four, injured forty; accused confessed, pleaded guilty, upheld by Supreme Court.

Case Summary (G.R. No. 47048)

Key Dates and Applicable Law

• Bombing: February 14, 2005
• RTC Decision: October 18, 2005
• CA Decision: June 30, 2008
• SC Decision: January 10, 2011
• Constitution: 1987 Philippine Constitution (post-1990 decision)
• Penalty Framework: Death penalty abolished by R.A. 9346; substituted by reclusion perpetua

Statement of Facts

• Two men (later identified as Baharan and Trinidad) boarded a southbound RRCG bus at Guadalupe-EDSA, acted suspiciously and paid fares twice.
• They insisted on alighting at Ayala Avenue; moments later, a bomb detonated, killing four and injuring about forty.
• Abu Sayyaf spokesperson publicly claimed responsibility and threatened further attacks.
• Pretrial stipulations and exclusive media interviews recorded confessions by Trinidad, Baharan, and Asali.
• Asali testified he was trained by Rohmat (Abu Jackie/Zaky) and others to build bombs, procured and supplied TNT on three occasions—including two failed attempts—culminating in the successful February 14 bombing.

Trial Court Proceedings

• Criminal Case No. 05-476 (multiple murder) and No. 05-477 (multiple frustrated murder) before RTC Makati.
• Initial pleas: Baharan, Trinidad, and Asali pled guilty to multiple murder; varied pleas on frustrated murder.
• Pretrial stipulations confirmed admissions of membership in Abu Sayyaf, knowledge of each other, admissions of causing explosion, and extrajudicial confessions in media interviews.
• Re-arraignment on frustrated murder: Baharan and Trinidad withdrew “not guilty” pleas and pled guilty after counsel’s explanation.
• Asali was discharged as state witness and testified to training and procurement details.

Assignments of Error

  1. Trial court failed to conduct a searching inquiry into the voluntariness and comprehension of the guilty pleas of Baharan and Trinidad.
  2. Guilt was not proven beyond reasonable doubt.

Searching Inquiry on Guilty Pleas

• Rule 116, Section 3, Rules of Court mandates a searching inquiry by the trial court to ensure an accused understands the nature and consequences of a guilty plea, especially in capital cases.
• Here, the court accepted plea changes based solely on defense counsel’s explanation, without personal interrogation of the accused.
• Jurisprudence requires judges themselves to satisfy that pleas are voluntary and fully comprehended.
• Despite procedural shortcomings, the Supreme Court deemed remand unnecessary because the guilty pleas were supported by prior extrajudicial confessions and judicial admissions, and were not the sole basis for conviction.

Sufficiency of Evidence

• Conductor Elmer Andales positively identified Baharan and Trinidad as the two men.
• Asali’s testimony detailed his supply of TNT to them and the planning stages of the bombing.
• Extrajudicial confessions in media interviews and pretrial admissions corroborated their participation.
• Independent and credible evidence satisfied the requirement of proof beyond reasonable doubt, sustaining both murder and frustrated murder convictions.

Criminal Liability of Rohmat Abdurrohim

• Charged as principal by inducement under Article 17, second paragraph, Revised Penal Code: he trained and directed Asali and Trinidad, providing instructions and materials without wh



...continue reading

Analyze Cases Smarter, Faster
Jur is a legal research platform serving the Philippines with case digests and jurisprudence resources.

About Privacy Terms