Case Summary (G.R. No. 133858)
Applicable Law
The case was adjudicated under the 1987 Philippine Constitution and the Rules of Court, specifically Rule 130, which governs admissions and confessions in the context of criminal trials.
Facts of the Case
On the early morning of May 25, 1997, the victim, Romero Pantilgan, was found dead with a gunshot wound to the head. The victim’s wife Gliceria and barangay officials testified on the discovery of the body and the subsequent police investigation. The appellant was alleged to have admitted to the killing before Barangay Captain Cynthia CastaAares and other officials. The murder weapon, a .38 caliber paltik revolver, was surrendered to authorities by appellant’s brothers, although their testimony was conflicting. The ballistic expert confirmed that the bullet recovered from the victim matched the surrendered firearm.
Prosecution Evidence and Confession
The prosecution’s case heavily relied on appellant’s alleged oral extrajudicial confession made before Barangay Captain CastaAares and two barangay kagawads. Appellant reportedly admitted to shooting the victim after being struck with a wooden piece during a struggle. This confession was not written or recorded but was given orally outside court proceedings. After the alleged confession, the appellant was taken to the police station, where he purportedly reiterated the admission, but no written statement was produced by police authorities.
Defense's Position and Contradictions
Appellant denied the charges, asserting he was asleep at the time of the killing, and disputed having confessed or surrendered the firearm. He also alleged enmity from a barangay official which could have motivated false accusations. His father and brothers supported his denial, contradicting prosecution testimony regarding the firearm and confession.
Legal Principles on Admission and Confession
Under Rule 130, Section 26 of the Rules of Court, an admission is a declaration relating to a relevant fact, while Section 33 defines a confession as a declaration by an accused acknowledging guilt. Confessions—judicial or extrajudicial—are admissible if made voluntarily and without compulsion. The hallmark of admissibility is voluntariness, which means the accused must freely and with full awareness of the consequences make the confession without inducement or coercion.
Challenges in Proving Voluntariness of Oral Extrajudicial Confession
Oral extrajudicial confessions pose evidentiary difficulties, primarily in proving voluntariness since there is no written document or direct court observation. Courts consider the accused's age, intelligence, character, and situation. In this case, appellant was a 19-year-old farmer with limited education, which impairs definitive assessment of the voluntariness and understanding of the confession’s consequences.
Requirement for Corroboration of Extrajudicial Confession
An extrajudicial confession by itself is not conclusive evidence of guilt. It must be corroborated with additional evidence that, when combined, establishes guilt beyond a reasonable doubt. Corroborating evidence need not be free from all variances with the confession but must tie the accused sufficiently to the crime's commission.
Analysis of Corroborative Evidence
Although ballistic evidence linked the fatal bullet to the firearm surrendered, proof that the firearm belonged to appellant was not conclusively established. There was conflicting testimony on the surrender of the gun, and no strong connection linked appellant with its possession. Additionally, physical evidence about the victim’s position during the shooting contradicted the narrative provided in the alleged confession.
Court’s Evaluation of Evidence and Admission
The trial court gave full credence to the oral confession and the testimonies supporting it. However, the Supreme Court found that the trial court erred in relying solely on these, as they lacked corroborative weight. The failure of police to reduce the confession to a written statement, coupled with appellant’s personal characteristics and inconsistent physical evidence, raised substantial doubts on the confession’s voluntariness and reliabi
...continue readingCase Syllabus (G.R. No. 133858)
Facts of the Case
- Appellant Herminiano Satorre (alias Emiano Satorre) was charged with murder for the shooting death of Romero Pantilgan on or about May 25, 1997, at approximately 2:00 AM in Sitio Kamari, Barangay Calidngan, Municipality of Carcar, Cebu.
- The victim was shot in the head with a .38 paltik revolver, using treachery and evident premeditation, resulting in instantaneous death.
- At arraignment, the appellant pleaded "not guilty" and the case proceeded to trial.
- Witnesses testified that the victim was found dead with a gunshot wound to the head, blood oozing from the wound.
- Barangay officials and relatives of appellant identified the weapon as the one used, supposedly surrendered by appellant’s brothers, and testified that appellant confessed to the killing.
- Appellant denied his guilt, ownership of the firearm, and the confession; he claimed to be asleep at the time of the incident.
- The trial court convicted appellant of murder and sentenced him to reclusion perpetua with indemnification to the victim’s heirs.
Issues on Appeal
- Whether the trial court erred in giving full credence to the prosecution’s witnesses.
- Whether due process was violated by denying appellant's motion for a preliminary investigation or reinvestigation.
- Whether the trial court erred in rejecting defense witnesses.
- Whether appellant’s alleged oral extrajudicial confession was admissible and sufficiently proved guilt beyond reasonable doubt.
Summary of Evidence Presented
- Testimony of Gliceria Saraum, the victim’s wife, who heard the gunshot, found the victim dead.
- Barangay kagawad Rufino Abayata confirmed the discovery of the body and reported the incident.
- Abraham Satorre, appellant’s father, reportedly informed barangay officials that appellant committed the shooting.
- Appellant's brothers allegedly surrendered the firearm used in the killing.
- Witnesses Flavio Gelle and Barangay Captain Cynthia CastaAares testified that appellant confessed to the killing during a meeting at the Barangay Captain's residence.
- Municipal Health Officer certified the cause of death as gunshot wound.
- NBI ballistics expert testified that the bullet recovered was fired from the surrendered firearm.
- Appellant and his family disputed all these claims, denying confession, ownership of the gun, and presence at the Barangay Captain’s house.
Legal Definitions and Applicable Rules
- Admission: An act, declaration, or omission by a party as to a relevant fact (Rule 130, Sec. 26, Rules of Court).
- Confession: Declaration by an accused acknowledging guilt of the offense charged or a necessarily included offense (Rule 130, Sec. 33