PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. AMANDO IMPERIO AND EUGENIO IMPERIO, DEFENDANTS-APPELLANTS.

People versus Imperio

The Case

This is a criminal case for murder. The People of the Philippines prosecuted Amando Imperio and his son Eugenio Imperio, father and son, for the killing of Gregorio Naval, the overseer and guard of a rice warehouse in San Lorenzo, Gapan, Nueva Ecija, whose body was found stabbed many times in the morning of March 6, 1962. The case matters to a Bar candidate because the Supreme Court, on automatic review of a death sentence, acquitted both accused on the ground of reasonable doubt, and in doing so gave a master class on how courts must scrutinize extrajudicial confessions, the conduct of police investigations, and the failure of the prosecution to present the best evidence.

Procedural History

A criminal complaint was filed against the two accused before the local justice of the peace court. The accused waived the second stage of the preliminary investigation and asked that the case be transferred immediately to the Court of First Instance. The Provincial Fiscal then filed the corresponding criminal information. After trial, the Court of First Instance of Nueva Ecija, in a judgment rendered on April 27, 1966, convicted both accused of murder, aggravated by three circumstances, and sentenced them to death, to indemnify the heirs of the victim in the amount of 6,000 pesos, with costs de oficio. Because the penalty imposed was death, the case went to the Supreme Court on automatic review. The Supreme Court reversed and acquitted.

Facts

In August 1961, Amando Imperio moved his family, including his son Eugenio, from San Ildefonso, Bulacan to San Lorenzo, Gapan, Nueva Ecija, while waiting to be settled in a job as overseer of a vegetable plantation. Father and son gathered grass for horse feed and worked as hired reapers and truck helpers. Occasionally they were hired to unload palay in the warehouse of one Doctor Borja, located just across the street from their house, a distance of twelve to sixteen meters. The overseer and guard of that warehouse was Gregorio Naval, known as Mang Godio, who usually slept there.

In the morning of March 6, 1962, Gregorio Naval was found dead inside the warehouse, his body bearing multiple stab wounds. The medical officer who examined the body found a stab wound on the chest, several stab wounds on the chest, abdomen, thighs, legs, back and forearm, contusions, and a stab wound of the liver. The cause of death was profuse hemorrhage, internal and external, due to stab wound. He testified that the victim could have died seven to ten hours before the autopsy, which was performed between nine and ten in the morning.

The prosecution's theory rested on two extrajudicial confessions. Amando allegedly confessed before the justice of the peace that he and his son hid inside the warehouse, waited until eleven o'clock at night, then attacked the victim, with Eugenio stabbing him lightly and Amando stabbing him in the stomach with a bolo. Eugenio allegedly confessed before the municipal mayor, corroborating the details. The police recovered a bolo and a dagger from the accused's house, and a flashlight from the warehouse. The accused, both illiterate though able to sign their names with difficulty, denied the killings and disowned the statements, claiming they did not know their contents and were forced to sign them. They testified that they spent the evening of March 5 at home and slept as early as seven o'clock.

Issues

• Whether or not the guilt of the accused was proven beyond reasonable doubt, considering the contradictions and gaps in the prosecution's evidence.
• Whether or not the extrajudicial confessions of the two accused were admissible and voluntary, given the circumstances of their execution.
• Whether or not the failure of the prosecution to present the bloodstained clothing and to subject the weapons to laboratory examination created reasonable doubt.

Applicable Provisions

The decision turns on the constitutional presumption of innocence, which the Court applies throughout. The 1935 Constitution, Article Three, Section One, provides:

No person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws.

This guarantee underlies the requirement that conviction rest on proof beyond reasonable doubt, not on suspicion or on doubtful confessions.

The Court also applies the rule that an extrajudicial confession must be voluntary and must be supported by independent evidence. The Revised Penal Code, Article 248, defines murder, but the Court's ruling rests on the failure of proof rather than on the elements of the crime.

Ruling

On the first issue, the Court held that the guilt of the accused was not proven beyond reasonable doubt. It listed fourteen circumstances casting grave doubt on the prosecution's case. Among them: the alleged confession of Amando said he left the bolo atop a palay bin near the back door of the warehouse, yet the police claimed they recovered it in his house under a bamboo bed inside a box wrapped with a sack. The bloodstained clothes Amando allegedly hid in the toilet were never recovered or presented, and no laboratory test was made to determine whether the stains on the weapons were human blood. The bolo bore the letters M Y, obviously not the initials of either accused, and no explanation was given. The flashlight was never shown to be relevant, and the confessions did not even mention it. The alleged motive of jealousy was pure hearsay, coming from relatives who were never presented, and the victim appeared to be an old and very thin man, possibly older than Amando, which tended to negate the alleged illicit relationship. The police never investigated other persons near the warehouse, including Conrado Marcelo, who was nearer and who was awakened by groans at eleven o'clock that night. The Court found it hard to imagine how the accused could have hidden inside the warehouse without the victim knowing, since they had been conversing with him near the door, and both lived only twelve to sixteen meters away and would have been missed at supper.

On the second issue, the Court held that the confessions could not be relied upon. Both were identically drafted, the only difference being an addendum in Amando's, and this circumstance neutralized their voluntary character. The testimonies of the police officers themselves were riddled with contradictions as to who investigated whom, when the statements were prepared, and who was present when they were signed. The Court noted that the alleged confessions were the product of a police investigation that left too many questions unanswered.

On the third issue, the Court held that the failure to present the bloodstained clothing and to subject the weapons to laboratory examination created reasonable doubt, because such evidence was available and could have settled the question of guilt.

Doctrine

First, an extrajudicial confession, to be admissible, must be voluntary and must be corroborated by independent evidence. Where the confessions are identically drafted and the police testimonies contradict each other on their execution, the confessions are unreliable.

Second, the prosecution must present the best evidence available. The failure to present bloodstained clothing and to subject weapons to laboratory examination, when such evidence could have been produced, creates reasonable doubt.

Third, motive must be proven by credible evidence, not by hearsay. The failure to investigate other persons with equal or better opportunity to commit the crime weakens the prosecution's case.

Fourth, the presumption of innocence prevails where the evidence is equivocal. The Court will not affirm a conviction on suspicion or on doubtful confessions.

Disposition

The Supreme Court reversed the judgment of conviction and acquitted both accused on the ground of reasonable doubt, with costs de oficio.

Remember This

The single line worth memorizing: a conviction cannot rest on doubtful confessions and missing evidence. Examiners use this case to test the requirements for a valid extrajudicial confession and the prosecution's duty to present the best evidence.