People vs. Aleman, et.

al, GR 185710, January 19, 2010

Facts: The accused Romulo Tuniaco, Jeffrey Datulayta, and Alex Aleman were charg
ed with murder. Police Officer Jaime Tabucon, on his arrival on the sub-station,
noted the presence of Atty. Ruperto Besinga, Jr. of PAO who was conversing with
those taken in custody for the offense. Tabucon took the statement of accused A
leman after informing him of his constitutional rights. Since accused Aleman sai
d he had no lawyer, Tabucon pointed to Atty. Besinga who claimed that he was ass
isting all the suspects in the case. Based on Aleman?s statement, the victim/dec
eased Dondon Cortez threatened to report his (Aleman) drinking companions? illeg
al activities to the police unless they gave him money. Since Datulayta and Tuni
aco had already planned to kill Cortez, they finally decided to do it. They got
Cortez drunk and led him to a demp site where Aleman stabbed him on the stomach,
Datulayta shot him on the head using his single shot homemade M16 pistol, and T
uniaco used the same gun on Cortez?s body. They covered the body with rice husks
. Accused Tuniaco filed a demurrer to evidence which resulted in the dismissal o
f the case against him. On being re-arraigned at his request, accused Datulayta
pleaded guilty to the lesser offense of homicide and he was sentenced by the tri
al court to imprisonment (6 years, 1 day). RTC found accused Aleman guilty of th
e crime charged.
Issues: (a) What is the doctrine of interlocking confessions ? (b) Did the accused
Aleman correctly invoke the Galit doctrine?
Ruling: (a) Under the doctrine of interlocking confessions, the corroboration of c
onfessions is circumstantial evidence against the person implicated in it. Thus,
in the case at bar, accused Datulayta?s confession corroborates that of Aleman
in important details. Hence, the contention of Aleman that his confession was fa
bricated and that the police forced him to sign it is improbable. More important
ly, the confession has details that only the person who committed the crime coul
d have possibly known.
(b) No. The accused Aleman incorrectly invoked the Galit doctrine. The doctrine
laid down in People v. Galit states that: long questions followed by monosyllabi
c answers do not satisfy the requirement that the accused is amply informed of h
is rights. The court held that this doctrine does not apply in the case at bar.
Police Officer Tabucon testified that he spoke to Aleman clearly in the language
he knew. Aleman, joined by Atty. Besinga, even signed a certification that the
investigator sufficiently explained to him his constitutional rights and that he
was still willing to give his statement.