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C3f - 5 - Frontreras v. People

The Supreme Court ruled that the petitioner's extrajudicial written confession was sufficient to prove her guilt beyond reasonable doubt. The confession letter was written and signed spontaneously by the petitioner. It contained coherent details that only the petitioner would know. Moreover, confessing to a crime is more serious than losing one's job, so it is implausible that the petitioner was coerced into confessing. The petitioner's statements showed she understood the consequences of confessing. The confession was therefore deemed voluntary and a valid evidence of guilt.

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1K views2 pages

C3f - 5 - Frontreras v. People

The Supreme Court ruled that the petitioner's extrajudicial written confession was sufficient to prove her guilt beyond reasonable doubt. The confession letter was written and signed spontaneously by the petitioner. It contained coherent details that only the petitioner would know. Moreover, confessing to a crime is more serious than losing one's job, so it is implausible that the petitioner was coerced into confessing. The petitioner's statements showed she understood the consequences of confessing. The confession was therefore deemed voluntary and a valid evidence of guilt.

Uploaded by

Aaron Ariston
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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3Cf- 5 – Confessions

Frontreras v. People
GR No. 190583
December 7, 2015

Reyes, J.:

FACTS:
On October 27, 1998, a surprise audit was conducted by Cebuana Lhuillier Pawnshop’s
(Cebuana) internal auditors where it revealed that 156 pieces of jewelry, with an aggregate value
of ₱1,250,800.00 were missing. A cash shortage of ₱848.60 was likewise discovered. When the
petitioner, Maria Paz Frontreras Y Ilagan (Frontreras), the vault custodian was asked to explain the
discrepancy, she told Mila Escartin (Escartin)(one of the internal auditors) that she would reduce
her explanation into writing. The next day, an audit report was sent to Marcelino Finolan (Finolan),
Area Manager of Cebuana. Upon receipt of the audit report on October 28, 1998, Finolan
immediately proceeded to the Old Balara branch to conduct an investigation. He called Escartin and
the petitioner for a meeting during which the petitioner handed over several pawn tickets while
Escartin gave him a handwritten letter made by the petitioner.

On May 10, 1999, an Information for Qualified Theft was filed before the RTC against the
petitioner, Salazar, and Carpon. Trial thereafter ensued. According to prosecution witness Finolan,
aside from receiving the petitioner’s handwritten letter on October 28, 1998, the petitioner also
gave him original pawn tickets, the back portion of which showed the signatures of their respective
pledgors. These signatures mean that the pledgors have already redeemed the jewelry covered by
each ticket by paying the amount for which they stand as a security. No payments were, however,
recorded nor turned over to the pawnshop. The petitioner also intimated to him that Carpon took
some of such cash payments but failed to return the same.

The RTC found sufficient circumstantial evidence establishing that the petitioner
perpetrated the offense but the petitioner’s co-accused Salazar and Carpon were acquitted on the
ground of reasonable doubt. The petitioner moved for reconsideration but her petition was denied
and appealed to the CA which upheld the lower court's conclusion. Hence, this petition.

ISSUE:
Whether the petitioner's extrajudicial written confession proves guilt beyond reasonable
doubt in this case?

HELD:
Yes. The Court ruled in the affirmative.

The petitioner wrote and signed the confession letter spontaneously. The language of the
confession letter was straightforward, coherent and clear. It bore no suspicious circumstances
tending to cast doubt upon its integrity and it was replete with details which could only be known
to the petitioner. Moreover, it is obvious that losing one’s job in an administrative case is less
cumbersome than risking one’s liberty by confessing to a crime one did not really commit. It is thus
implausible for one to be cajoled into confessing to a wrongdoing at the mere prospect of losing
his/her job. The petitioner’s declarations to Talampas (one of the auditors) show that she fully
understood the consequences of her confession. She also executed the letter even before Finolan
came to the Old Balara branch, thus, negating her claim that the latter threatened her with an
administrative sanction.

A confession, whether judicial or extrajudicial, if voluntarily and freely made, constitutes evidence
of a high order since it is supported by the strong presumption that no sane person or one of normal
mind will deliberately and knowingly confess himself to be the perpetrator of a crime, unless
prompted by truth and conscience. The admissibility and validity of a confession, thus hinges on its
voluntariness, condition vividly present in this case.

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