G.R. No. 36173 ; November 25, 1932
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. MARIA ORIFON, defendant-appellant.

FACTS

Maria Orifon was convicted of murder for killing her father and sentenced to cadena perpetua. She initially pleaded guilty during the preliminary investigation but entered a not guilty plea at arraignment. The primary evidence against her was her detailed written confession in the Ilocano dialect, where she admitted to the killing. She described that her motive was shame and desperation after her father had repeatedly raped her, threatening to kill her and her mother if she revealed the abuse. At trial, her counsel did not object to the admission of this confession. On appeal, her counsel raised only a technical objection regarding the Spanish translation of her Ilocano confession not being formally certified.

ISSUE

Whether the Spanish translation of the appellant’s Ilocano confession is admissible and sufficient to sustain her conviction.

RULING

Yes, the conviction is affirmed but modified. The Court held the confession admissible. A member of the Court verified the substantial correctness of the Spanish translation, satisfying the requirement for its consideration. The Court found sufficient corroborative evidence independent of the confession to warrant its admission. The penalty was modified from cadena perpetua (which no longer existed under the Revised Penal Code) to reclusion perpetua with its accessory penalties. While affirming the judgment under the strict letter of the law, the Court, with profound regret, expressed its opinion that the penalty was clearly excessive given the circumstances—the appellant’s prolonged sexual abuse by her father and her resulting disturbed state. It invoked Article 5 of the Revised Penal Code to submit this view to the Chief Executive for possible executive clemency.

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