Case Summary (G.R. No. L-29979)
Key Dates
- Incident Date: April 7, 1967
- Trial Court Decision Date: September 18, 1968
- Supreme Court Decision Date: September 28, 1979
Applicable Law
- Revised Penal Code of the Philippines
- Article 48 concerning complex crimes
- Article 248 regarding Murder
Case Background
The respondents, alongside several others, were implicated in a violent incident involving the use of dynamite against two Philippine Constabulary (PC) officers and a civilian, resulting in their deaths. The trial court found them guilty, imposing the death penalty on Patuhin, Jamari, and Mohamadsali due to the heinous nature of their acts, while Cosing received life imprisonment due to his minority.
Charges and Evidence
The prosecution’s evidence outlined a coordinated assault involving multiple accused who conspired to throw dynamite at the officers despite Supreme Court witnesses failing to observe the actual event due to its location in an uninhabited area. Following their arrests, confessions were taken that implicated the accused in the violent acts constituting murder and direct assault, although defense claims emerged asserting those confessions were obtained under duress.
Verdict from Lower Court
The trial court, upon reviewing evidence, concluded that there was a conspiratorial agreement among the accused, citing that despite the absence of all conspirators in one place, their collective actions amounted to concerted criminal activity, leading to a murder conviction. The court noted the existence of aggravating circumstances but ruled that no mitigating factors applied in this grave matter.
Appeal Assertions
The appellants raised multiple errors against the trial court’s findings:
- The trial court erred by convicting them when the evidence didn’t explicitly show their participation in the acts causing the victims’ deaths.
- They argued that even accepting the admissibility of their confessions, the prosecution did not sufficiently establish a conspiracy among them.
- They contended that the court inaccurately classified Sapal Jabal as an accessory.
- They questioned the admissibility of their extrajudicial confessions, claiming coercion.
Supreme Court Decision
The Supreme Court affirmed the trial court’s reliance on the extrajudicial confessions, declaring them admissible, asserting that evidence demonstrated a community of criminal purpose. The Court also provided that:
- The confessions, purported to be coerced, were found to have been given freely and voluntarily, as substantiated by testimonies from officers involved in gathering those statements.
- A conspiracy was inferred from the actions o
Case Syllabus (G.R. No. L-29979)
Case Overview
- The case involves an automatic review by the Supreme Court of the judgment from the Court of First Instance of Davao.
- The judgment was dated September 18, 1968, and pertained to Criminal Case No. 10537.
- The defendants include Tambutso Patuhin, Jayri Jamari, Tambusong Mohamadsali, and Samindi Cosing, with the latter receiving a sentence of life imprisonment.
- The trial court sentenced Patuhin, Jamari, and Mohamadsali to death for multiple murders with direct assault upon persons in authority.
Charges and Verdict
- The Information charged twelve accused with "Multiple Murder with Direct Assault Upon Agents of Persons in Authority" as per Article 48 of the Revised Penal Code.
- The prosecution alleged that on April 7, 1967, the accused conspired to use dynamite to attack PC Sergeants Bonifacio Bonutan and Salvador Geraldo, resulting in their deaths, along with that of civilian Felix Bildera.
- The trial court's dispositive portion indicated guilt for the accused, emphasizing the absence of mitigating circumstances and presence of aggravating factors, leading to the imposition of the death penalty.
Summary of Evidence Presented
- On the day of the incident, the two PC sergeants were conducting an investigation related to reported dynamite fishing.
- They apprehended several individuals with dynamited fish and were towing their bancas when another boat containing the accused intercepted them.
- The accused threw sticks of dynamite at the PC motorboat, leading to the explosion and the subsequent deaths of the PC soldiers and