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
...continue readingCase Syllabus (G.R. No. L-36824)
Case Overview
- Court: Supreme Court of the Philippines
- Decision Date: September 11, 1979
- Citation: 181 Phil. 391; 76 OG No. 25, 4273 (June 23, 1980)
- Case Number: G.R. No. L-36824
- Parties Involved:
- Plaintiff-Appellee: The People of the Philippines
- Defendants-Appellants: Ariston Guillermo, Carlito Aborde, Ronito Cullo, and Jesus Cullo
- Nature of the Case: Appeal from a judgment of conviction for Robbery in Band with Homicide.
Background of the Case
- The accused were charged in Criminal Case No. 1830 for robbery in band with homicide.
- The trial court found all four accused guilty beyond reasonable doubt, sentencing them to reclusion perpetua and ordering them to indemnify the victims' parents.
Incident Details
- Date of Incident: May 10, 1972
- Location: Barrio Lamonan, Passi, Iloilo
- Victim: Billardo Gardoce was shot and killed during the robbery perpetrated by the accused.
- Details of the Robbery:
- The accused, armed with homemade shotguns, threatened the Gardoce family and demanded money and firearms.
- Vicente Gardoce, the father, was coerced into giving P500 and a homemade shotgun after threats of harm to his sons.
Prosecution's Evidence
- Testimonies were provided by family members Vicente and Benedicto Gardoce detailing the sequence of events during the robbery.
- Witnesses testified to the involvement of the accused during the crime, including the shooting of Billardo Gardoce by Ariston