Case Digest (G.R. No. 206226)
Facts:
The People of the Philippines charged Nieves Constancio y Bacungay and Ernesto Berry y Bacungay with Rape with Homicide arising from the abduction, rape, and killing of "AAA" on the night of March 11, 2001 in Paranaque City; they pleaded not guilty, were convicted by the Regional Trial Court, Branch 258, Paranaque City on January 22, 2007 and sentenced to reclusion perpetua, and the Court of Appeals affirmed on February 24, 2012. Both appellants appealed to the Supreme Court, which rendered its decision on April 4, 2016.
Issues:
- Did the Court of Appeals err in crediting the prosecution witnesses' identifications of the appellants?
- Did the Court of Appeals err in admitting Ernesto Berry's extrajudicial confession and in using it against Constancio?
- Did the Court of Appeals err in finding the appellants guilty beyond reasonable doubt?
Ruling:
The Court denied the appeal and affirmed the decision of the Court of Appeals finding Constancio and Berry guilty beyond reasonable doubt of Rape with Homicide and upholding their sentences of reclusion perpetua. The Court modified the awards of civil indemnity, moral damages, and exemplary damages to P100,000.00 each, and imposed interest at six percent per annum from finality.
Ratio:
The Court deferred to the factual findings on witness credibility as affirmed by the CA because the trial court observed witness demeanor and the appellants failed to show overlooked material facts or misappreciation that would affect the outcome. The Court held Berry's Sinumpaang Salaysay admissible because it was executed voluntarily with the assistance of a competent and independent counsel, and his statements to a reporter were voluntary and thus admissible. An extrajudicial confession by one accused is generally not binding on co-accused but may be used as corroborative circumstantial evidence when other circumstantial facts (eyewitness identifications and overt acts such as disposal of the body) together with the confession establish participation beyond reasonable doubt.
Doctrine:
- Trial court findings on witness credibility, affirmed by the Court of Appeals, will not be disturbed on appeal unless material facts were overlooked or misappreciated.
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