People Vs Satorre

(2) People vs Emiano Satorre
Gliceria Saraum, wife of the victim Romero Pantilgan, testified that she and her two children were asleep
inside the house of her parents. Romero, went out to attend a fiesta. While she was asleep, she was
awakened by a gunshot, got up, went out to the porch, found her dead husband on the ground. Abayata,
barangay kagawad, testified that he and barangay kagawad, Alvarado, confirmed the incident and
reported it to the Carcar Police. Rufino narrated that Satorre’s father, informed them that it was Satorre
who shot Pantilgan. Satorre’s brothers surrendered to Rufino the gun allegedly used by Satorre. Gelle
narrated that he accompanied Satorre and his to the Brgy Capt. Castaares where appellant admitted killing
Pantilgan. He was detained. Castaares corroborated the said testimony. Appellant allegedly informed her
that he killed Pantilgan because the latter struck him with a piece of wood. He denied the crime of murder
charged against him, claimed that he was asleep inside his house at the time of the incident. He denied
having confessed to the killing of Pantilgan. He disclaimed ownership over the revolver and stated that he
could not even remember having surrendered a firearm to Castaares. His father corroborated appellants
testimony who denied having accompanied appellant to Castaares house to surrender him.
ISSUE: WON the oral extrajudicial confession is made voluntarily and shall be admissible as evidence.
HELD: No. A confession, as distinguished from an admission, is a declaration made at any time by a
person, voluntarily and without compulsion or inducement, stating or acknowledging that he had
committed or participated in the commission of a crime. Appellants alleged declaration owning up to the
killing before the Brgy Capt. was an oral extrajudicial confession because was not put in writing and
made out of court. There is no question as to the admissibility of appellants alleged oral extrajudicial
confession. Rules of Court makes no distinction whether the confession is judicial or extrajudicial. The
question is the validity of the confession whether it was voluntarily and freely made. The age, character,
and circumstances prevailing at the time it was made, intelligence of the accused or want of it must be
considered. Satorre was a 19-year old farmer who did not even finish first grade. Granting that he made
the confession, he may not have realized the full import of his confession and its consequences. Due to
the personal circumstances of appellant, voluntariness of his oral confession may not be definitively
appraised and evaluated.
Appellant allegedly admitted before policemen that he killed Pantilgan. His statement was not taken nor
was his confession reduced into writing. This circumstance casts doubt not only as to the voluntariness of
the a confession, but also on whether appellant made an oral confession. A confession is not required to
be in any particular form. However, it is advisable, if not otherwise recorded by video tape or other
means, to reduce the confession to writing, should be read to the defendant, have it read by defendant,
have him sign it, and have it attested by witnesses.
The events alleged in the confession are inconsistent with the physical evidence. Acc. to Castaares,
appellant narrated to her that during the struggle between him and the deceased, he fell to the ground after
the latter hit him on the head with a piece of wood. In the autopsy report, the entrance wound on the
deceased was at the top of the head, indicating that the victim was probably lying down when shot. An
extrajudicial confession will not support a conviction where it is uncorroborated. The prosecution was not
able to conclusively establish the ownership of the gun other than the bare testimony of prosecution
witnesses that appellants brothers surrendered the gun to them. This was denied by appellant and his
brothers and there was no other proof linking the gun to him. ACQUITTED

People Vs Satorre

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(2) People vs Emiano Satorre

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