PEOPLE OF THE PHILIPPINES v.

DOMINGO REYES, ALVIN ARNALDO, and JOSELITO FLORES

G.R. No. 178300 | March 17, 2009 | Ponente: CHICO-NAZARIO, J.

FACTS:
On July 16, 1999, accused-appellants herein, Reyes, Arnaldo, and Flores, together with other
accused at-large, kidnapped the Yaos (Robert Yao, Yao San, Raymond Yao, Ronald Matthew
Yao, Lennie Yao, Charlene Yao), and Chua Ong Ping Sim, Jona Abagtnan, and Josephine Ortea,
holding them against their will and consent on board a Mazda MVP van for the purpose of
extorting PHP 5,000,000.00; during the detention, the accused strangled to death Chua Ong Ping
Sim and Raymond Yao.

Arnaldo surrendered to the Presidential Anti-Organized Crime Task Force at Camp Crame, and
with the assistance of Atty. Uminga, executed a written extra-judicial confession narrating his
participation in the kidnapping. Likewise, Flores, with the assistance of Atty. Rous, executed the
same. The trial court found the appellants herein guilty of special complex crime of kidnapping
for ransom with homicide, sentencing them to death (the death penalty was not yet suspended at
the time of the decision). With the death penalty being imposed, it was elevated to the Supreme
Court for automatic review, but was remanded to the Court of Appeals for proper disposition,
pursuant to the Court’s ruling in People v. Mateo. The CA modified the decision, imposing
reclusion perpetua without parole, instead of the death penalty. With their motion for
reconsideration denied, the appellants thus filed this instant petition.

ISSUE:
Whether the extra-judicial confessions of the accused are admissible in evidence.

RULING:
YES. The Supreme Court held that the extra-judicial confessions made by Arnaldo and Flores
are admissible in evidence. For an extra-judicial confession be admissible in evidence, the
following requisites must be satisfied: (1) it must be voluntary; (2) it must be made with the
assistance of competent and independent counsel; (3) it must be express; and (4) it must be in
writing.

It was found by the Court that the prosecution has sufficiently established that the extra-judicial
confessions made by Arnaldo and Flores were obtained in accordance with the constitutional
guarantees. The burden of proving that undue pressure or duress was used to procure the
confessions rest on Arnaldo and Flores, which they failed to overcome.

The Court stated: Since the prosecution has sufficiently established that the respective extra-
judicial confessions of appellant Arnaldo and appellant Flores were obtained in accordance with
the constitutional guarantees, these confessions are admissible. They are evidence of a high order
because of the strong presumption that no person of normal mind would deliberately and
knowingly confess to a crime, unless prompted by truth and conscience.”