Case Digest: People vs Manigbas, 109 Phil 469(1960), G.R. Nos. L-10352-53

People vs Manigbas, 109 Phil 469(1960), G.R. Nos. L-10352-53, September 30, 1960

Subject: Basic Legal Ethics

FACTS

On July 9, 1954, Manigbas and his men gathered at the house of Catalino Ramos in barrio Macalamcam, Rosario. Manigbas told his men that Esteban de Guzman, the Chief of Police of Rosario, must be killed because he was responsible for the conviction and sentence to double life imprisonment of their "boss" Isaac Farol. Manigbas then called for volunteers who would be the trigger men.

Marcial Macalintal, Lope de Torres, and Amado Ramos responded and volunteered to perform the job. With the exception of Miguel Almario and Catalino Ramos, who remained behind, Manigbas and his men (composed of Tomas Carandang, Iluminado Landicho, Isabelo Egar, Alejandro Zuño, Ben Mercado, Melecio Sison, Eugenio Mendoza alias Eugenio Hernandez, and Eliseo Carandang) went to the house of Esteban de Guzman and shot him dead.

The men were arrested and charged with murder. They all pleaded not guilty. At trial, the prosecution presented the testimony of Tomas Carandang, who had been a member of Manigbas's commando unit. Carandang testified that he had witnessed the planning and execution of the murder of Esteban de Guzman. The defense argued that Carandang's testimony was unreliable because he had been promised leniency in exchange for his testimony. The defense also argued that the prosecution had not presented any physical evidence linking the men to the crime. The trial court found the men guilty of murder and sentenced them to death. The men appealed their convictions to the Supreme Court.

ISSUE

Whether or not the confessions of Eliseo Carandang, Eugenio Mendoza, Modesto Leviste, and Isabelo Egar were admissible in evidence. 

RULING

No. The accused argued that the confessions were inadmissible because they were obtained through coercion. They argued that the accused were threatened with physical harm and that they were promised leniency if they confessed.

The prosecution argued that the confessions were voluntary. They argued that the accused were not threatened or promised anything in exchange for their confessions. The Supreme Court held that the confessions were admissible in evidence. The Court found that there was no evidence that the accused were coerced into confessing. The Court also found that the accused were not promised anything in exchange for their confessions.

In this case, the Supreme Court's decision has been criticized by some legal scholars. Some scholars have argued that the Court's decision makes it too easy for the prosecution to obtain confessions from suspects.