Case Digest (G.R. No. 140740)
Facts:
People of the Philippines v. Juanito Baloloy, G.R. No. 140740, April 12, 2002, the Supreme Court En Banc, Per Curiam. The prosecution charged Juanito Baloloy (accused-appellant) with rape with homicide under Article 335 of the Revised Penal Code as amended by R.A. No. 7659 (Criminal Case No. AZ-CC-96-156). Upon arraignment on December 10, 1996, Baloloy pleaded not guilty; trial followed in the Regional Trial Court (originally decided by Judge Loreto C. Quinto). This decision is the mandatory automatic review by the Supreme Court of a death sentence.On the evening of August 3, 1996, the 11‑year‑old victim Genelyn Camacho was reported missing after leaving to borrow rice. Her body was later found floating at a waterfalls in Barangay Inasagan; it bore multiple injuries including fresh lacerations of the vagina. Villagers recovered a black rope and an umbrella near the crime site. Baloloy originally claimed he discovered the body while catching frogs and he accompanied others to retrieve the corpse.
Barangay Captain Luzviminda Ceniza testified that when she asked who owned the black rope turned over to her at the wake, Baloloy admitted ownership and, upon being urged to “tell everything,” voluntarily narrated to her that he had raped Genelyn (inserting fingers and thereafter a larger object or organ) and threw her body into the ravine; Ceniza also observed wounds and scratches on Baloloy which he attributed to the victim biting him. Police later took custody of Baloloy and took affidavits of witnesses; a complaint was filed the next day.
Presiding Judge Celestino V. Dicon testified that, while administering oaths to witnesses in his courtroom on August 4, 1996, he asked Baloloy whether the charge was true; Baloloy replied that he was “demonized” but thereafter spontaneously told Judge Dicon that he struck Genelyn with a stone and dumped her body. Baloloy was never assisted by counsel during his encounters with the police or when he made statements to Ceniza and Judge Dicon.
At trial the prosecution presented eyewitnesses and medical testimony (Dr. Arturo Lumacad) describing the victim’s injuries and the abrasions on Baloloy; the defense presented Baloloy’s denial and alibi, asserting he had been at his mother’s house and that he merely discovered the body. The trial court convicted Baloloy beyond reasonable doubt of rape with homicide and sentenced him to death, ordering P50,000 indem...(Subscriber-Only)
Issues:
- Was Baloloy’s extrajudicial confession to Barangay Captain Luzviminda Ceniza and to Presiding Judge Celestino V. Dicon obtained in violation of his constitutional rights under Article III, Section 12(1) of the 1987 Constitution and therefore inadmissible?
- If the confession(s) are excluded, did the prosecution nevertheless prove Baloloy’s guilt beyond reasonable doubt on the basis of the remaining (largely circumstantial) evidence; and is the death penalty and civil...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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