People of the Philippines vs. Guillermo, Aborde, and Cullo
## Facts:
1. **Incident**: On May 10, 1972, at around 5:30 A.M. in Barrio Lamonan, Passi, Iloilo, Billardo Gardoce was killed with a homemade shotgun during a robbery.
2. **Crime Scene Details**:
– Vicente Gardoce and his family were in their house when they were awakened by barking dogs.
– Vicente’s son Benedicto went to investigate, followed by brothers Godofredo, Rufino, and Billardo.
– Accused Ariston Guillermo and Carlito Aborde apprehended and tied the hands of Benedicto, Godofredo, and Rufino.
– Ronito and Jesus Cullo held them at gunpoint.
– Billardo was shot by Ariston Guillermo when he approached and asked what was happening.
– Vicente Gardoce handed over P500 in cash, a revolver, and a homemade shotgun under threat.
3. **Apprehension and Investigation**:
– Ariston Guillermo and Carlito Aborde were arrested on May 10, 1972.
– Both were allegedly forced to sign extrajudicial confessions after maltreatment.
– Ronito and Jesus Cullo were arrested on May 19, 1972, and subjected to police maltreatment but refused to sign confessions.
4. **Trial Court**:
– Found Ariston Guillermo, Carlito Aborde, and the Cullo brothers guilty of robbery in band with homicide.
– Sentenced each to reclusion perpetua and ordered them to indemnify the victims.
5. **Appeals**:
– All defendants appealed, questioning the admissibility of the extrajudicial confessions, the credibility of prosecution witnesses’ testimonies, and their conviction basis.
– Guillermo and Aborde additionally claimed they were framed.
– The Cullo brothers denied participation and provided an alibi supported by witnesses.
## Issues:
1. **Admissibility of Extrajudicial Confessions**:
– Whether the trial court erred in admitting the extrajudicial confessions of Guillermo and Aborde, given the allegations of force and coercion used to obtain these confessions.
2. **Credibility of Prosecution Witnesses**:
– Whether the testimonies of Vicente and Benedicto Gardoce contain inconsistencies that should affect their credibility and the weight of their evidence.
3. **Identification and Participation of Cullo Brothers**:
– Whether there was sufficient evidence to identify and prove that Ronito and Jesus Cullo participated in the crime.
4. **Overall Conviction Basis**:
– Whether the guilt of all accused was proven beyond reasonable doubt based on the evidence presented.
## Court’s Decision:
1. **Extrajudicial Confessions (Exhibits “A” and “B”)**:
– **Admissibility**: The Supreme Court ruled that the extrajudicial confessions were inadmissible as they were obtained under duress and threat, violating the constitutional right against self-incrimination (Sec. 20, Art. IV, 1973 Constitution).
– **Precedent Overturned**: The ruling in People vs. de los Santos that admissibility is unaffected by the illegality of means was declared obsolete.
2. **Credibility of Prosecution Witnesses**:
– **Circumstantial Evidence**: The Supreme Court maintained the credibility of Vicente’s and Benedicto’s testimonies in describing Guillermo’s and Aborde’s participation in the crime but found inconsistencies regarding the Cullo brothers.
3. **Identification and Participation of Cullo Brothers**:
– **Serious Doubt on Identification**: Initial affidavits by Vicente and Benedicto did not identify the Cullo brothers. The original complaint named different individuals (Estorques) as companions, indicating uncertainty and casting doubt on the Cullo brothers’ alleged participation.
– **Verdict for Cullo Brothers**: The Court acquitted Ronito and Jesus Cullo due to reasonable doubt.
4. **Overall Conviction Basis**:
– **Guillermo and Aborde**: The Court affirmed the conviction of Guillermo and Aborde based on consistent direct evidence pointing to their obvious participation.
– **Cullo Brothers**: The convictions were reversed due to lack of conclusive evidence of their participation.
## Doctrine:
The exclusionary rule in Philippine jurisprudence emphasizes that any confession obtained through force, violence, or intimidation is inadmissible in evidence. This doctrine ensures the protection of constitutional rights against self-incrimination and guarantees due process.
## Class Notes:
Key Elements:
1. **Extrajudicial Confessions** (Sec. 20, Art. IV, 1973 Constitution):
– Must be voluntary, not extracted by coercion, violence, or intimidation.
– Violations render confessions inadmissible.
2. **Admissibility of Evidence**:
– Evidence obtained unlawfully (e.g., through malpractices) is inadmissible.
3. **”Res Inter Alios Acta” Rule**:
– Declarations implicating co-accused are admissible only against the declarant unless conspiracy is independently proven.
4. **Reasonable Doubt Standard**:
– A conviction must be based on evidence proving guilt beyond reasonable doubt, ensuring no substantive doubt about the defendant’s involvement.
## Historical Background:
In the early 1970s Philippines, crime rates and extrajudicial activities by police were notable concerns. The case reveals the tension between law enforcement practices during that period and emerging constitutional mandates for protecting individual rights. The Supreme Court’s decision marked a significant step in reinforcing the protection of constitutional rights against self-incrimination amidst allegations of police excesses.
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