Title
People vs. Guillermo
Case
G.R. No. L-36824
Decision Date
Sep 11, 1979
Robbery with homicide in 1972; Guillermo and Aborde convicted based on credible testimonies, Cullo brothers acquitted due to insufficient evidence and coerced confessions excluded.

Case Summary (G.R. No. L-36824)

Facts of the Case

On May 10, 1972, at approximately 5:30 A.M., an incident occurred at the residence of Vicente Gardoce and his wife, Demetria Castor, wherein their son, Billardo Gardoce, was shot and killed during a robbery. The assailants, identified as the defendants, allegedly demanded money and firearms from Vicente Gardoce, threatening the safety of his sons. The prosecution’s case was primarily supported by the testimony of Vicente and Benedicto Gardoce, who detailed the events leading to the shooting of Billardo Gardoce by Ariston Guillermo, and the robbery that included threats and violence.

Legal Proceedings and Accusations

The trial court found the defendants guilty beyond reasonable doubt of robbery in band with homicide, primarily based on witness testimonies and extra-judicial confessions attributed to Ariston Guillermo and Carlito Aborde. Each defendant was sentenced to reclusion perpetua and ordered to indemnify the heirs of the victim.

Extrajudicial Confessions Controversy

The admissibility of the alleged extrajudicial confessions (Exhibits "A" and "B") signed by Guillermo and Aborde was contested. Defendants argued these confessions were obtained under duress, citing maltreatment and coercion from police officers during their detention. The trial court initially accepted these confessions as evidence, invoking earlier precedents that allowed for some flexibility regarding the means by which evidence was acquired.

Examination of Evidence

The review determined that the method of obtaining the confessions violated constitutional protections against self-incrimination. It was highlighted that the confessions were prepared in English, a language the accused did not understand, and both men initially refused to sign them until threatened with further harm. Furthermore, municipal judge testimony suggested that the confessions were taken under questionable circumstances, showing doubt regarding their voluntariness.

The Court’s Ruling

The Supreme Court, upon review, concluded that the reasonable doubts concerning the voluntariness of the confessions should favor the accused, rendering the confessions inadmissible. Regarding the Cullo brothers, the Court found insufficient evidence to establish their involvement in the crime, primarily due to discrepancies in witness testimonies regarding their participation. Thus, their convictions were reversed and set as

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