Case Summary (G.R. No. L-65165)
Events Leading to the Crime
Manuel Pascual was approached by the five accused who lured him into drinking gin. Following a drunken spree, an altercation ensued where Pascual was violently attacked, eventually resulting in his death from multiple stab wounds. Key evidence included eyewitness testimony and extrajudicial confessions from the accused detailing their coordinated assault on Pascual.
Charges and Initial Proceedings
On November 12, 1981, the five were charged with murder marked by aggravating circumstances: treachery, evident premeditation, abuse of superior strength, and drunkenness. During the trial, three of the accused issued confessions and later altered their pleas. Ambrocio and Aglugob accepted guilt, while Martinez retracted his admission of guilt.
Trial Court's Decision
On July 29, 1983, the trial court convicted Mateo and Dajugar of murder, sentencing them to reclusion perpetua (life imprisonment) and ordering them to compensate the victim's heirs. Only Dajugar appealed the verdict, arguing his confession was improperly admitted based on alleged maltreatment and inadequate legal representation.
Legal Standards Governing Confessions
Under Article IV, Section 20 of the Constitution, individuals are entitled to the right against self-incrimination and must be informed of their rights before interrogation. Additionally, the Revised Penal Code mandates that individuals in detention be informed of the reason for their detention and of their right to counsel.
Evaluation of Dajugar's Confession
The court examined the validity of Dajugar's confession while noting that his rights might not have been fully upheld during the interrogation. Despite his claims, the presence of corroborative extrajudicial confessions from his co-accused supported the prosecution's case against him.
Findings on Participation and Penalty
The court confirmed sufficient evidence of Dajugar's active participation in the murder, but disputes arose concerning the classification of the crime's aggravating factors. Dajugar's age and the nature of his intoxication were cite
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Case Background
- This case concerns the murder of Manuel Pascual, a 34-year-old tricycle driver, whose body was discovered on October 9, 1981, near the Mariano Marcos State University in Laoag City.
- Pascual sustained thirteen incised and stab wounds, indicating a violent death that occurred the night prior to the discovery of his body.
- Evidence included Pascual's tricycle found abandoned and a bolo recovered near the scene of the crime.
Arrest and Confessions
- On October 23, 1981, five suspects were apprehended: Fidel Mateo (20), Elmer Dajugar (18), Rene Ambrocio (15), Florante Martinez (15), and Edwin Aglugob (15).
- The accused provided extrajudicial confessions detailing how they had engaged Pascual in a drinking spree before attacking him.
- Mateo initiated the plan to kill Pascual as a vendetta for a prior altercation.
The Incident
- The group invited Pascual to drink gin after boarding his tricycle.
- They subsequently stopped the tricycle on the way to the mayor's residence, where an altercation ensued.
- Pascual attempted to escape but was caught, stabbed, and ultimately his body was disposed of in his own tricycle.
Eyewitness Testimony
- Froilan Ramirez, a 16-year-old eyewitness, testified he saw Pascual being chased and assaulted by the accused around 9 PM on October 8, 1981.
- His testimony corroborated the sequence