Criminal Case Digest: PEOPLE VS MADLANGBAYAN

PEOPLE VS MADLANGBAYAN
Criminal Case Digest
Digested Cases
Criminal Law


FACTS: Antonio Madlangbayan y Bonet was convicted of the crime of robbery with homicide and there being proved the aggravating circumstance of abuse of superior strength without any mitigating circumstance to offset the same, the Lower Court sentences him to DEATH
On appeal, the accused who admitted to being a member of the Bahala Na Gang, now maintains that his extrajudicial confession was coerced from him. He claims that when he refused to affix his thumbmark to Exhibit E, he was boxed by Patrolman Cuevas and his companions.
ISSUE:
 Whether the extrajudicial confession is sufficient to sustain the conviction.
HELD:
The Rules of Court provide that "An extrajudicial confession made by an accused shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti.

In this case, from the evidence of the prosecution, apart from the extrajudicial confession of the appellant, the fact of the commission of the crime of robbery with homicide, is well and sufficiently established. Said fact, which is the corpus delicti of the offense charged has been proved by the uncontradicted testimonies of Elywelyn Fallarme and the police officers assigned to this case, as well as by the testimony of Dr. Abelardo Lucero, the police medical examiner, as to the death of Enrique Fallarme, together with the documentary evidence of the necropsy report stating the post- mortem findings, including the cause of death.


Finally, it is manifest that the accused together with his co-assailants who unfortunately have not been apprehended, took advantage of their superior strength, when the four of them, two of whom were armed with bladed weapons surrounded and stabbed the unarmed, helpless and unsuspecting victim. The aggravating circumstance of abuse of superior strength was correctly appreciated by the trial court.

WHEREFORE, finding the accused guilty beyond reasonable doubt of the crime of robbery the homicide, the judgment under review is hereby affirmed in its entirety.

SO ORDERED.


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