2-4. People v. Guting

People of the Philippines v. Adrian Guting y Tomas GR No. 205412 September 9, 2015 Facts:

On a rainy afternoon of July 30, 2005, at around 5 o’clock, PO1 Fidel Torre and PO1 Alexis Macusi were standing in front of the Camiling Police Station when the accused-appellant, all wet from the rain and with a bladed weapon in his hand, suddenly approached them and told them that he had stabbed his father. Hearing such statement, PO1 Torre immediately got the bladed weapon from the accused-appellant and turned it over to PO1 Macusi for proper disposition. The accused-appellant proclaimed that his father was already dead. Unsuspecting, PO1 Macusi asked who killed the victim. The accused-appellant answered, “Sinaksak ko po yung Tatay ko! Napatay ko po!” PO1 Torre then gotthe knife from theaccused-appellant and gave to PO1 Macusi who placed the same in the police station’s custodian cabinet. Thereafter, several officers went to the residence of Jose Guting to verify the reported crime while other police officers informed Flora Guting, the victim’s wife about the incident. SPO2 Felipe inquired from the neighbors if anybody had witnessed the crime but no one did. Subsequently, Jose was brought to the nearest hospital where he was pronounced dead on arrival. A complaint against accused-appellant was then filed for Parricide. On cross-examination, PO1 Macusi divulged that when the knife was given to him by PO1 Torre for safekeeping, he did not ask the accused-appellant if it was the knife he used to kill his father. Neither did accused-appellant mention to him that it was the knife he used in stabbing the victim. The RTC promulgated its decision on June 24, 2020 finding the accused-appellant guilty of Parricide based on his verbal admission that he killed his father. Even assuming that the accusedappellant’s admission was inadmissible in evidence, the RTC adjudged that the prosecution was able to establish sufficient circumstantial evidence which, taken collectively, pointed to the accused-appellant as the perpetrator of the crime. In the CA, the appeal was denied and the decision of the RTC was affirmed. Hence, this petition to the SC. Issue: Was the extra judicial admission by the accused enough to convict him? Held: Yes. The allegation of the accused-appellant that the evidence is inadmissible for the blatant violation of Sec. 12 of Art. III of the Bill of rights is incorrect. The SC held that the “investigation” in Section 12, par. 1 of Article III of the Constitution pertains to custodial investigation. This commences when a person is taken into custody and is singled out as a suspect in the commission of a crime under investigation and the police officers begin to ask questions on the suspect’s participation therein and which tend to elicit an admission. Applying the same, the accused-appellant was not under custodial investigation. His verbal confession was so spontaneously and voluntarily given and was not elicited through questioning by

the police authorities. He was arrested and subjected to custodial investigation only after his confession. Hence, the accused-appelant’s confession, even if done without the assistance of a lawyer, is not in violation of his constitutional right under Section 12 of Article III of the present Constitution. The declaration is admissible as part of the res gestae. All the requisites of the case are present in this case. His confession was further corroborated by the circumstantial evidence. Therefore, his conviction is upheld.