Case Summary (G.R. No. L-62617-18)
Incident Overview
On the evening of August 6, 1979, Colana, Magabilen, and others waited at the corner of Claro M. Recto Avenue and Oroquieta Street for members of the Alpha fraternity. Upon identifying de la Vega, Magabilen seized him, while Colana assaulted him with an icepick. De la Vega was outnumbered and sustained multiple stab wounds that ultimately led to his death from internal hemorrhage.
Motive and Background
The motivation behind the attack was described as revenge, stemming from an earlier incident where members of the Phi Lambda Epsilon fraternity were beaten by associates of the Alpha fraternity. During trial proceedings, both Colana and Magabilen denied their involvement in the crime, with Colana disavowing his initial confession, claiming he was not involved in the killing, and attributing the acts to Bravo and Caneda.
Extrajudicial Confession and Its Admissibility
A critical aspect of the case involved the admissibility of Colana's extrajudicial confession, made after his arrest on September 19, 1979. The confession was taken by Patrolman Reynaldo H. Jaylo and included a detailed acknowledgment of Colana's rights under the Constitution. The confession was signed by Colana and corroborated by physical evidence linking him to the crime, including the icepick identified in his confession.
Evidence and Testimony
The coroner's report indicated that the victim had suffered several punctured wounds, consistent with an icepick's use. Despite the defense's plea of mistaken identity for de la Vega as he was not a member of the rival fraternity, Bravo's testimony aligned with Colana's confession and established a clear narrative of Colana’s involvement. The confession and witness corroboration provided sufficient evidence to satisfy the prosecution's burden of proof.
Legal Findings and Conclusion
The court upheld that Colana voluntarily, knowingly, and intelligently waived his rights during police interrogation. The evidence demonstrated his guilt was established beyond reasonable doubt. The c
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Background of the Case
- The case involves the appeal of Leonardo A. Colana from the decision of the Circuit Criminal Court of Manila.
- Colana and his co-accused, Jorge Magabilen, were found guilty of murder during a fraternity rumble.
- The court sentenced both to reclusion perpetua and ordered them to indemnify the heirs of the victim, Librado de la Vega, in the amount of P84,000.
- The case arose from an incident on August 6, 1979, involving members of the Phi Lambda Epsilon fraternity and the Alpha Kappa Rho fraternity.
Parties Involved
- Accused-Appellant: Leonardo A. Colana, aged 26, an officer of the Phi Lambda Epsilon fraternity.
- Co-Accused: Jorge Magabilen, aged 22, president of the same fraternity.
- Victim: Librado de la Vega, aged 21, who sustained fatal injuries during the incident.
- State Witness: Carlito Bravo, a member of the Alpha Kappa Rho fraternity, who testified against Colana and Magabilen.
Incident Details
- The assault occurred at approximately 8:00 PM at the intersection of Claro M. Recto Avenue and Oroquieta Street.
- The accused and their accomplices waited for members of the rival fraternity to pass by.
- Librado de la Vega was wrongly identified as a member of the rival fraternity and was subsequently assaulted.
- Magabilen held De la Vega while Colana stabbed him with