Evidence Cases Dianne

Case #10 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 got the knife from the accused-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 crossexamination, PO1 Macusi divulged that when the knife was given to him by PO1 Torre for safekeeping, he did not ask the accusedappellant 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 accused-appellant’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.

ISSUES:

1. Whether the trial court gravely erred in convicting the accused-appellant on the basis of his extrajudicial admission; 2. Whether the trial court gravely erred in convicting the accused-appellant on the basis on insufficient circumstantial evidence.

HELD:

The petition is unmeritorious. The allegation of the accusedappellant 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. As to the second issue, 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.

Case #11 Vicente H. Manulat, Jr. v. People of the Philippines GR No. 190892, August 17, 2015

FACTS:

Petitioner is the husband of the deceased Genebe Manulat. In the afternoon of September 4, 2005, Mary Jane Soriano, a neighbor

of the spouses, heard the spouse quarreling. She heard petitioner telling Genebe “Day, If I get hurt I would box you.” She also heard sounds of breaking ceramics and a thud, then there was silence. At around 6:40 in the evening of the same day, petitioner with their two children went to his mother-in-law Carmen and confided to her the incident. After dinner, petitioner left his children with his mother-in-law and went home at 11 o’clock in the evening. The following morning, Carmen, bathed the two children and asked them what happened. Leslie Kate, their two-year old daughter answered, “Father threw the cellphone, mother’s mouth bled,” while Vince Earl, their threeyear old son said, “Father choked mama” and “Mama was left home dead.” Carmen did not mind what the children said and instead told them that their mother was on duty at Gold City. Around 4 o’clock in the afternoon of the same day, a neighbor rushed to the house of the spouses upon hearing petitioner’s shout for help. She saw Genebe hanging from the ceiling on top if the bed Then, petitioner slipped out the knot and laid the body of his wife on the bed while crying. Petitioner did not do anything but cry and asked his wife why she had done it. Around 5 o’clock of the same day, the police officers arrived after receiving a call from the barangay kagawad pertaining to the incident. SPO3 Bonifacio Santillana told the petitioner to bring his wife to the hospital for they might resuscitate her. The petitioner replied that he could not come with her because he still has to inform his parents-in law. Santillana detached the rope and noticed that the noose could not be tightened. Doubting the real cause of death of their daughter, Carmen and her husband went to the office of CIDG and requested assistance for the autopsy of the cadaver of Genebe. The Medical Examiner concluded that Genebe died of asphyxia by strangulation. The RTC rendered a decision proclaiming the accused guilty beyond reasonable doubt of the crime charged. Such decision was affirmed by the CA. Hence, this petition to the SC.

ISSUE:

Whether or not the CA erred in affirming the decision of the RTC that there is sufficient circumstantial evidence exists to establish the guilt of the accused-petitioner by reasonable doubt.

Held:

The SC do not agree with the contentions of the petitioner. Although there was no eyewitnesses or direct evidence presented that categorically point to the petitioner as the one who killed his wife, there was also no direct evidence establishing that the victim took her own life. It is settled that the lack or absence of direct evidence does of necessarily mean that the guilt of the accused cannot be proved by evidence other than direct evidence. The crime charged may be proved also by circumstantial evidence. In this case, the circumstantial evidence at hand convincingly prove petitioner’s culpabilities in the crime, and foreclose the possibility that another person is liable for it or the victim took her own life. The testimonies of the witnesses and all other circumstantial evidence are consistent with each other clearly establishing that the victim was killed by her own husband and not by the claim of the accused that his wife took his own life. The statements of the petitioner and their children were spontaneously made. These constitute res gestae. The requisites for the statements to be classified as res gestae are present in this case. It has always been said that criminal cases are primarily about human nature. This is a case of a husband refusing to rush his wife to the hospital even for the possibility of resuscitation for flimsy reasons that there was nobody left at their house and that he still had to inform his parent-in-law. It is noted that from the time he supposedly discovered his wife, he only cried, he did not exert any effort to rush her to the hospital, and instead, waited for the police officers to arrive. Such inaction of a supposed loving husband is contrary to human nature. All considered, the CA did not err in affirming the trial court’s conclusion that the presumption of innocence of petitioner has been overcome by the totality of the physical and testimonial evidence against him.