People of the Philippines v. Rodrigo Dasig et al.
Facts:
On August 4, 1987, Police Officer (Pfc.) Redempto Manatad, along with two other officers, was assigned to man traffic in Mandaue City. That afternoon, eight individuals acting suspiciously were noticed by Pfc. Rene Catamora, who identified one as Edwin Nuñez. Observing two of the men approach Pfc. Manatad, Catamora followed but was drawn into a gun battle which allowed the others to shoot Manatad, ultimately resulting in his death.
Subsequent investigations led to a surveillance operation on August 16, 1987, at a suspected hideout of the Sparrow Unit (alleged assassination squad of the New People’s Army) in Cebu City. Here, Rodrigo Dasig and Edwin Nuñez were found trying to escape. Nuñez was captured, while Dasig, after resisting arrest and getting shot, was also apprehended. Evidence, including firearms and an extra-judicial confession, were gathered against Dasig.
In the trial court, Dasig contested the validity of his confession, which he argued was taken in violation of his constitutional rights. Moreover, Nuñez changed his plea to guilty but died during the trial, extinguishing his criminal liability. Dasig was convicted of Murder with Direct Assault. He appealed the decision to the Supreme Court, arguing the procedural deficiencies in his interrogation, the misclassification of his crime, and physical condition during confession.
Issues:
1. Whether the extra-judicial confession of the appellant was voluntarily and legally made in the presence of competent and independent counsel.
2. Whether appellant’s crime should be classified as Murder with Direct Assault or as a political crime of simple rebellion.
Court’s Decision:
The Supreme Court found appellant’s extra-judicial confession voluntary and legally made. The Court recognized the regularity of the confession and the active participation of his counsel. Atty. Fortunato Parawan testified to assisting the appellant, who consented to his services, throughout the entire interrogation process.
On the issue of the crime classification, the Court agreed with the appellant’s and the Solicitor General’s position that the correct charge was simple rebellion. The killing was deemed as an act committed in furtherance of rebellion and was absorbed into the single crime of rebellion. The Indeterminate Sentence Law does not apply to rebellion.
Finally, the appellant was sentenced to eight (8) years of prision mayor for simple rebellion, and ordered to pay civil damages to the heirs of Pfc. Manatad.
Doctrine:
Acts committed during rebellion are considered absorbed by the political crime and cannot serve as the basis for separate charges of common crimes, such as murder.
Class Notes:
– Extra-judicial confessions are admissible if made voluntarily and with the presence of counsel.
– The voluntary nature of a confession is presumed unless the accused successfully proves coercion or duress.
– Rebellion is a political crime that can absorb common crimes committed in its furtherance.
– Indeterminate Sentence Law does not apply to those convicted of rebellion.
Historical Background:
This case occurred during a period of significant political turmoil in the Philippines, characterized by the presence of insurgent forces opposing the government. The New People’s Army, which Dasig and co-accused were alleged members, has been involved in an ongoing conflict against the government. The context highlights the intersection of common crimes with political objectives and the court’s approach to handling cases occurring within a broader political struggle.
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