PEOPLE OF THE PHILIPPINES, PLAINTIFF AND APPELLEE, VS. JORGE FELICIANO Y GARCIA AND ABRAHAM GARCIA Y PURIFICACION, DEFENDANTS AND APPELLANTS.

People versus Garcia

The Case

This is the People of the Philippines against Jorge Feliciano y Garcia and Abraham Garcia y Purificacion, a criminal prosecution for robbery with homicide. The two accused were charged with conspiring to take a passenger jeepney from its owner, Alberto Ila, and with killing him on the occasion of that robbery. The case matters to a reviewee because it gathers in one decision several rules that examiners love: the weight given to extrajudicial confessions repudiated at trial, the effect of a confession sworn before a police officer rather than a fiscal or judge, the irrelevance of motive once identity is established, and the rule on venue in criminal cases where the offense straddles several localities.

Procedural History

The two accused were arraigned before the Court of First Instance of Manila, Branch Seventeen, and both pleaded not guilty. After trial, the court rendered judgment finding them guilty beyond reasonable doubt of robbery with homicide, with the aggravating circumstances of craft, nighttime, abuse of superior strength, and use of a motor vehicle, and without any mitigating circumstance. The trial court imposed the extreme penalty of death and ordered them to indemnify the heirs of the deceased, plus the value of the unrecovered jeepney. Because a death sentence was imposed, the case went to the Supreme Court on automatic review. The Supreme Court affirmed the conviction and the civil liabilities, but reduced the penalty to reclusion perpetua for lack of the required votes to impose death.

Facts

Alberto Ila, also known as Alberto Salamat, was a married man with two children who earned his living driving a passenger jeepney along the Divisoria to Quiapo route. On the eighth of February, 1967, he took his jeepney out to solicit passengers and never returned. His wife Virginia grew apprehensive, tried to locate him, and reported his disappearance to the police on the morning of the tenth of February. A taxi driver and neighbor later told her that he had seen her husband driving his jeepney northbound on the national highway near the San Miguel Brewery plant in Valenzuela, Bulacan, with three or four passengers aboard.

On the eleventh of February, a body was discovered in Barrio Salangan, San Miguel, Bulacan, concealed inside a burlap sack among the tall grasses. The police found the victim naked, his hands bound and his face covered with cloth, his arms bound to his bent knees with abaca twine and tie wire in a squatting position. The medico-legal officer found tie marks on the wrists and ankles, a lacerated wound on the right occipital side that could have been caused by a blunt instrument, and a gunshot wound on the right chest, which he attributed as the cause of death. Virginia Ila supplied the identifying marks of her husband, including a tattoo on the left leg, and the body was exhumed and examined. A fingerprint expert of the Manila Police Department compared the post-mortem fingerprints with the standard fingerprints of Alberto Salamat on file and concluded they were the same, noting thirteen identical characteristics.

Investigation led to the arrest of Jorge Feliciano and Abraham Garcia. They signed statements, and later gave subsequent separate statements in which they narrated how they lured the victim to Marilao, Bulacan, on the pretext of fetching a woman. Feliciano admitted he bore a grudge against Alberto, whom he suspected of having triggered his dismissal from his job. He stated that he struck the victim with an iron pipe while Garcia and a companion identified as Ding used pieces of wood, that a companion identified as Rene wielded the gun, and that all of them helped tie the victim and slip him into a burlap sack. A re-enactment of the crime was held and photographed. At trial, both accused repudiated their confessions, admitted the genuineness of their signatures, and claimed the statements were extracted by force and third degree methods. The trial court rejected the claim of maltreatment, and the Supreme Court found no error in admitting the confessions.

Issues

• Whether or not the trial court erred in admitting the extrajudicial confessions despite the accused's claim that they were extorted by force and maltreatment.
• Whether or not the confessions are invalid because they were subscribed and sworn to before the Chief of the Detective Bureau rather than before a fiscal or a judge.
• Whether or not the absence of an eyewitness and of proof of motive weakens the prosecution's case.
• Whether or not the Court of First Instance of Manila had jurisdiction, given that the body was found in Bulacan and there was no direct evidence of where the victim was killed.

Applicable Provisions

Section 14, paragraph (a) of Rule 110 of the Revised Rules of Court, on the place where a criminal action must be instituted and tried, provides:

Section 14 (a) — In all criminal prosecutions the action shall be instituted and tried in the court of the municipality or province wherein the offense was committed or any one of the essential ingredients thereof took place.

This provision is the basis for the Court's holding that Manila had jurisdiction, because the conspiracy and the luring of the victim began in Manila, an essential ingredient of the offense.

Ruling

On the first issue, the Court held that the trial court did not err in admitting the confessions. The claim of maltreatment was belied by the accused's own testimonies. The trial judge observed that if Garcia had truly been maltreated every day for two weeks, his signatures on statements taken days apart would have shown a marked difference, yet they were written with the same sure and firm hand. The Court also stressed that the statements were replete with details the police could not have concocted, such as Feliciano's lack of a driver's license a week before his arrest, his quarrel with a relative of the deceased, and his school records, and that these details dovetailed with the findings of the medico-legal officer. The accused likewise re-enacted the crime before many spectators and before the camera without being pressured into posing. The Court applied the settled rule that the findings of the trial judge are not to be disturbed on appeal absent substantial facts overlooked that might affect the result.

On the second issue, the Court held that the confessions were valid even though sworn before a police officer. It quoted its own ruling that there is no provision of law which prescribes that either confessions or admissions are not competent evidence unless made under oath, and that it is the fact that they are voluntarily made by the accused and against his own interest which gives them their evidentiary value. The Court added that confessions are not even required to be in writing, that the fact they were made while under arrest did not render them inadmissible since they were made prior to the adoption of the 1973 Constitution, and that they were made in Tagalog, a dialect fully within the comprehension of the accused.

On the third issue, the Court held that while motive is important, when there is no longer any doubt that the defendant was the culprit, it becomes unimportant to know the exact reason for the crime, and the failure to establish motive becomes inconsequential. The Court entertained no doubt that the defendants committed the crime.

On the fourth issue, the Court held that Manila had jurisdiction. Since the commission of the crime was started in Manila, in front of the Vista Theater along Claro M. Recto Avenue, where the victim was lured into going with the defendants, an essential ingredient of the offense took place there, and the Court of First Instance of Manila unquestionably had jurisdiction.

Doctrine

A confession derives its evidentiary value from the fact that it is voluntarily made by the accused against his own interest; it need not be under oath, need not be in writing, and is not rendered inadmissible merely because it was taken while the accused was under arrest or because it was sworn before a police officer rather than a fiscal or judge. The claim of maltreatment is weighed against the accused's own conduct, including the firmness of his signatures and his voluntary participation in a re-enactment. The findings of the trial judge on the credibility of witnesses and on the voluntariness of a confession are not disturbed on appeal absent substantial overlooked facts. Motive becomes inconsequential once the culprit's identity is established beyond doubt. Finally, under Section 14, paragraph (a) of Rule 110, venue lies in the court of the municipality or province where the offense was committed or any one of the essential ingredients thereof took place, so that where the conspiracy and the luring began in Manila, Manila has jurisdiction even if the killing occurred elsewhere.

Disposition

The Supreme Court affirmed the judgment of conviction and the civil indemnities, but reduced the penalty from death to reclusion perpetua with all accessory penalties, for lack of the required votes to impose the extreme penalty, with costs against the accused.

Remember This

Memorize this line: a confession's value lies in its voluntariness and its being against the accused's interest, not in the oath or the officer before whom it was sworn. Examiners use this case for the venue rule in Rule 110, where any essential ingredient of the offense fixes jurisdiction, and for the rule that motive is unimportant once identity is certain.