G.R. No. L-30577 - People vs. Obedoza

Case Summary (G.R. No. L-30577)

Factual Background

On the night of May 28, 1967, while Maximiniano Cabangcala, his wife Isabel Dacanay, and their two grandchildren were at their house in Barrio Salagusog, several armed persons took away four carabaos (three males and one female) and one cow. When Cabangcala heard the firing of guns, he jumped out of the window and was hit by pellet gunshots on his right leg. Dr. Pio Alberto, the Municipal Health Officer of Cuyapo, examined Cabangcala on May 29, 1967, and reported that the pellet wounds had a diameter of six inches and were caused by a .12 gauge shotgun. Gangrene later developed. Cabangcala was advised that amputation of the wounded leg was necessary, but he refused. He consequently died on June 13, 1967.

The stolen animals were covered by certificates of ownership of large cattle. The identity of the perpetrators was not immediately established. Investigation continued until October 24, 1967, when police inquiry allegedly led to the confession of Lauro Alcantara.

Confessions and Alleged Participation

According to the prosecution narrative, Lauro Alcantara pointed to Quines Linda, Ben Bocasas, Lucio Paldeng, Londring Martinez, and Jessie Quitan as his companions in the theft of the carabaos and cow, and as the group that caused Cabangcala to be shot. Alcantara allegedly stated that Ben Bocasas was the one who shot Cabangcala and Quines Linda was the one who sold the stolen animals. Alcantara also allegedly pointed to Ambrocio Sumalbag as their informer as to where cattle could be stolen.

Ricarte Obedoza (alias Alfonso Obedoza), also allegedly implicated by Alcantara, was then investigated. Obedoza allegedly executed a confession admitting he was with the group on May 28, 1967, and that Ben Bocasas shot Cabangcala under the orders of Ambrocio Sumalbag.

Procedural History in the Trial Courts

Based on these investigations, a complaint for “Robbery in Band with Homicide” was filed in the Municipal Court of Cuyapo on November 22, 1967 against the named accused. On November 27, 1967, the complaint was amended to include Quines Linda. After preliminary investigation, the case was forwarded to the Court of First Instance of Nueva Ecija, Branch IV, at Guimba. The Provincial Fiscal filed an information dated March 18, 1968, charging the accused with robbery in band with homicide, alleging that the accused, armed with firearms, conspired to take and steal the cow and carabaos belonging to Cabangcala and, on the occasion of the robbery, fired shots at Cabangcala, thereby inflicting serious injuries that caused his death.

Only Londring Martinez, Ambrocio Sumalbag, and Lauro Alcantara were arraigned and tried; the rest remained at large. Quines Linda was not included as an accused. The trial court, in its decision dated March 26, 1969, convicted these three and sentenced each to life imprisonment, with accessory penalties and indemnities based on three-eighths of the value of the stolen animals, plus three-eighths of the costs. Ambrocio Sumalbag and Londring Martinez appealed.

Prosecution’s Evidence at Trial

The prosecution claimed that, after the crime on May 28, 1967, Cuyapo police were initially unable to identify those responsible for Cabangcala’s death. Investigation resumed after police received information that Lauro Alcantara had been apprehended in Balungao, Pangasinan for stolen kitchen utensils sometime in October 1967. A police team led by Sgt. Rufino de Gracia allegedly interviewed Alcantara and obtained an alleged admission to a series of offenses, including the robbery at Barrio Salagusog. Alcantara was placed under temporary custody and brought to Cuyapo for investigation.

There, Alcantara allegedly confessed his participation in several offenses in Cuyapo, and the alleged confession was reduced to writing, subscribed, and sworn before the Municipal Judge of Cuyapo. The written narrative stated that on the night of May 28, 1967, Alcantara and companions, including Londring Martinez, took four carabaos and a cow after Ben Bocasas shot the owner; they then brought the animals to Sto. Tomas, Pangasinan, where Quines allegedly sold them for P350, which was divided among them. It also identified Bernabe Baclig as mastermind and identified Ambrocio Sumalbag as the informer.

After Alcantara was brought back to Balungao, police allegedly discovered that Ricarte Obedoza was confined in the Balungao municipal jail. Obedoza and Alcantara were then brought to Cuyapo, where Obedoza was investigated by Cuyapo police Lt. Casimiro Aguinaldo and allegedly confessed his participation. His confession was likewise reduced to writing, substantially affirming Alcantara’s narrative, and was sworn before the Municipal Judge of Cuyapo. Obedoza and Alcantara were also brought to the scene of the crime for a re-enactment. The prosecution supported its theory primarily through these alleged extra-judicial confessions and their corroboration by the testimonies of police officers and medical evidence.

At trial, only five prosecution witnesses testified: Isabel Dacanay and Rosendo Encomienda (widow and son-in-law of Cabangcala), Sgt. de Gracia and Lt. Aguinaldo (Cuyapo Police Force), and Dr. Pio Alberto. The widow testified about the robbery and her husband’s being shot but could not identify the malefactors at the time. Encomienda testified that he was about two kilometers away when the incident occurred, and he stated that before the incident Cabangcala had sought Ambrocio Sumalbag for help in recovering two stolen carabaos. The police witnesses testified about the investigation and the alleged extra-judicial confessions. Dr. Alberto testified about the nature of the pellet wounds that later led to gangrene and death.

Defense Theory and Alibis

The defense consisted of denials and alibis, and it challenged the admissibility and credibility of the alleged confessions.

Lauro Alcantara claimed that on May 28, 1967, he was at Barrio San Vicente, Rosales, Pangasinan, because he was courting someone, and that he slept at 6:30 p.m. and woke at 7:00 a.m. He further stated that in May 1967 he was arrested at Barrio San Vicente by police officers, that he was maltreated, and that he was forced to admit being a thief. He alleged he was tortured and compelled to confess that Sumalbag was the commander and that Londring Martinez was his companion. He insisted that he became aware of them only in later places and times and that he signed the confession only because of threats. He added that he could not read or write and that his alleged confession was written in English without translation to Ilocano. He also denied knowledge of the victim and of Exhibit “G.”

Eufemio (Londring) Martinez claimed that on May 28, 1967, he was in Sto. Tomas, Pangasinan, with his wife and six children; he slept at about 7:00 p.m. and woke at 5:00 a.m. the next day. He stated that he did not know Barrio Salagusog, Cuyapo, or Nueva Ecija, did not know Cabangcala and his wife, did not know police officer Rufino de Gracia and Lauro Alcantara, and did not know anything about Exhibit “G.” He said he only came to know Alcantara at the Cabanatuan jail and Sumalbag only in July 1968 during trial, both of whom were unknown to him on the date of the crime.

Ambrocio Sumalbag asserted that on May 28, 1967, he was at his house in Sinimbaan, Cuyapo, Nueva Ecija, as a barrio councilor and a confidential agent of the governor; he slept with his wife and children. He argued that Barrio Salagusog was about four kilometers away from Barrio Sinimbaan and claimed he voluntarily surrendered on January 30, 1968. He also claimed he knew Cabangcala and trusted him.

Issues Raised on Appeal

The appellants advanced several grounds for reversal. They challenged the trial court’s treatment of Exhibit “G”, a sketch allegedly showing the positions of companions during the crime. Appellants pointed out that the trial court stated Ricarte Obedoza made the sketch, but they argued it was actually prepared by Sgt. Rufino de Gracia, and that Exhibit “G” was signed by Sgt. de Gracia only on October 23, 1968, when he testified in court. They further stated that the conformity of Lauro Alcantara and Ricarte Obedoza to Exhibit “G” was never obtained and that they did not sign it. They argued that Alcantara denied knowledge of Exhibit “G,” and that any mention of the accused in the exhibit appeared to be the narration and view of the police sergeant, not an admission by the accused. Thus, they contended that Exhibit “G” had no probative value as hearsay.

They also challenged the trial court’s conclusion that their failure to object to the extra-judicial confessions of Alcantara and Obedoza made the confessions admissible against them. According to appellants, their counsel objected to the confessions being admissible against them, and trial counsel never cross-examined police witnesses specifically on the contents of the alleged confessions.

Finally, appellants argued that even assuming admissibility, the confessions lacked voluntariness and credibility. They pointed to allegations that Alcantara was illiterate, not represented by counsel during the investigation, and had confessed only after alleged force and threats. They also argued that the supposed confession of Obedoza could not support conviction because it was not tested in a way that could establish its veracity, and because Obedoza was never brought to trial in the case.

Supreme Court’s Evaluation of Confessions and Evidence

The Court observed that the alleged confessions were the principal evidence supporting conviction. It examined the trial court’s finding that appellants’ lack of objection to the extra-judicial confessions rendered them admissible against them. The Court held that the record showed otherwise: the appellants’ counsel did not cross-examine Sgt. de Gracia on the substance of the alleged confessions (Exhibits “F”, “H”, and “G”), and counsel similarly did not cross-examine Lt. Aguinaldo about Obedoza’s alleged confession

Case Syllabus (G.R. No. L-30577)

Parties and Procedural Posture

The case was an appeal by Ambrocio Sumalbag and Londring Martinez from a judgment convicting them of robbery in band with homicide.
The People of the Philippines prosecuted the remaining accused who were tried, namely Lauro Alcantara, Londring Martinez (also referred to as Eufemiano Martinez), and Ambrocio Sumalbag, while the other accused stayed at large.
The trial court rendered its conviction in a decision dated March 26, 1969.
The Supreme Court reversed the conviction and acquitted Sumalbag and Martinez with costs de oficio.
Aquino, J. voted in the result, while Barredo (Chairman), Abad Santos, and De Castro, JJ. concurred.

Key Factual Allegations

The prosecution alleged that on the night of May 28, 1967, at Barrio Salagusog, Cuyapo, Nueva Ecija, armed persons took away four carabaos (three male and one female) and one cow from Maximiniano Cabangcala and his wife Isabel Dacanay, who were with their two grandchildren.
The prosecution claimed that after Cabangcala heard gunfire, he jumped out of the window and was hit by shotgun pellets on his right leg.
Dr. Pio Alberto examined Cabangcala on May 29, 1967 and testified that the gunshot wounds caused by pellets were about six inches in diameter and were caused by a .12 gauge shotgun.
The prosecution alleged that gangrene developed, Cabangcala was advised to undergo amputation but refused, and he died on June 13, 1967.
The prosecution asserted that the stolen animals were covered by certificates of ownership of large cattle.
The prosecution alleged that identification of the malefactors was not immediately possible and only later resulted from investigation, including alleged confessions.
The prosecution narrated that Lauro Alcantara was apprehended in October 1967 while carrying stolen kitchen utensils, and he was brought to Cuyapo for investigation.
The prosecution asserted that Alcantara allegedly confessed his participation in the Barrio Salagusog robbery, named supposed companions (Quines Linda, Ben Bocasas, Lucio Paldeng, Londring Martinez, and Jessie Quitan), and identified Ambrocio Sumalbag as their informer in Cuyapo.
The prosecution further alleged that Alcantara named Ben Bocasas as the shooter who shot Cabangcala and named Quines Linda as the one who sold the stolen animals.
The prosecution claimed that after Alcantara’s investigation, Ricarte Obedoza was found and investigated, and he allegedly confessed actual participation in the crime.
The prosecution alleged that Obedoza’s confession, reduced to writing and sworn before the Municipal Judge of Cuyapo, substantially affirmed Alcantara’s version.
The prosecution alleged that Obedoza and Alcantara were brought to the scene for a re-enactment and described their relative positions during the commission of the crime.
The prosecution’s information alleged that the accused acted in conspiracy, used firearms, took the animals with intent to gain, and that on the occasion of the robbery they shot Cabangcala causing death.

Evidence Presented at Trial

The trial involved only five prosecution witnesses: Isabel Dacanay, Rosendo Encomienda, Sgt. Rufino de Gracia, Lt. Casimiro Aguinaldo, and Dr. Pio Alberto.
Isabel Dacanay, the victim’s widow, testified on the manner of the robbery and the shooting but could not identify the malefactors at the time of the incident.
Rosendo Encomienda, the victim’s son-in-law, testified that he was about two kilometers away at the time of the incident and that prior to the event the victim sought assistance from Ambrocio Sumalbag to recover stolen carabaos.
Sgt. Rufino de Gracia and Lt. Casimiro Aguinaldo testified about the investigation and the alleged extra-judicial confessions of Alcantara and Obedoza.
Dr. Pio Alberto testified on the nature of the pellet wounds and confirmed that the refusal of amputation was a factor in Cabangcala’s death.
The conviction, as characterized by the Supreme Court, relied essentially on the alleged extra-judicial confessions (Exhibits mentioned as “F,” “H,” and a sketch “G”) rather than on independent eyewitness identification.

Defense Theories and Contentions

The defense presented alibis for each appellant and denied knowledge of the alleged participants and scene.
Lauro Alcantara claimed that on May 28, 1967 he was in Barrio San Vicente, Rosales, Pangasinan because he was courting someone, and he described his arrest and alleged maltreatment leading to coerced confession.
Alcantara alleged that he was forced to confess that Ambrocio Sumalbag was their commander and was forced to point to Londring Martinez as a companion, and he asserted that he only came to know them later in custody.
Alcantara claimed he did not even know Barrio Salagusog, Cuyapo, Nueva Ecija, and he asserted that he signed the confession because of threats to shoot him or to have him eliminated.
Alcantara denied knowledge of the victim Cabangcala, denied knowledge of the sketch appearing in Exhibit “G”, and claimed that his alleged confession was written in English without translation to his dialect; he asserted he was illiterate and never went to school.
Eufemio (Londring) Martinez claimed that on May 28, 1967 he was in Sto. Tomas, Pangasinan with his wife and children, and he denied knowing the victim, the police officer Rufino de Gracia, or Lauro Alcantara.
Martinez claimed he knew Alcantara and Sumalbag only later during detention and trial, and he denied understanding Exhibit “G”.
Ambroc