Case Digest (G.R. No. 216064)
Facts:
In Criminal Case No. 07-257131, PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. ANTONIO DACANAY Y TUMALABCAB, ACCUSED-APPELLANT was charged with Parricide under Article 246 of the Revised Penal Code for the October 6, 2007 stabbing death of his wife, Norma E. Dacanay. The son found the victim lifeless; accused allegedly confessed to reporters while in a detention cell, jewelry later recovered from his locker matched missing items, a medico-legal report confirmed death by puncture wounds, the RTC convicted on June 21, 2011, the Court of Appeals affirmed on April 2, 2014, and the accused appealed to the Supreme Court.Issues:
- Was the extrajudicial confession of the accused inadmissible because it was given under a coercive physical or psychological atmosphere?
Ruling:
The appeal was dismissed for lack of merit and the Decision of the Court of Appeals affirming the conviction for Parricide under Article 246 was AFFIRMED. The Court MODIFIED the judgment to awar Case Digest (G.R. No. 216064)
Facts:
- Background of the charge and parties
- PEOPLE OF THE PHILIPPINES, plaintiff-appellee, filed an Information charging ANTONIO DACANAY Y TUMALABCAB, accused-appellant, with the crime of Parricide under Art. 246, Revised Penal Code.
- The Information alleged that on or about October 6, 2007, in Manila, accused with intent to kill stabbed his wife, Norma Dacanay y Ero, several times with an ice pick, inflicting mortal wounds which caused her death.
- Discovery of the victim and initial circumstances
- On October 6, 2007, Norma was found lifeless on the bathroom floor of the marital home by the couple’s son, Quinn, with several puncture wounds; the house appeared in disarray.
- Antonio had left for work at around six in the morning that day.
- Quinn informed his aunt, Beth Bautista, and then went to Antonio’s workplace at PHIMCO Industries, Inc., then returned home; police were already investigating when they returned.
- Police investigation and initial statements
- PO3 Jay Santos inspected the crime scene and interviewed Antonio, who informed him that P100,000.00 in cash and jewelry were missing and mentioned an alleged “Miller” as Norma’s supposed lover.
- Antonio initially declined to formalize his statement at the precinct citing funeral arrangements and promised to come the next day but did not do so.
- On October 8, 2007, Antonio and Quinn proceeded to the police station when invited again; Barangay Kagawad Antonio I. Nastor, Jr. and members of the media were present.
- Extrajudicial confession to the media and corroborating acts
- While at the precinct and after being apprised of constitutional rights, Antonio repeatedly confessed to reporters that, following a quarrel over the missing P100,000.00, he stabbed his wife around 4:00 a.m., threw away the instrument, staged the scene to look like a robbery, and stored missing jewelry in his locker at PHIMCO.
- Media men Nestor Etolle (Philippine Star) and Jun Adsuara (Tanod Diyaryo ng Bayan) testified that Antonio voluntarily admitted his complicity without intimidation or coercion.
- A news article entitled “Mister timbog sa pagpatay sa asawa” appeared in Tanod Diyaryo ng Bayan on October 10, 2007.
- A follow-up operation by PO3 Santos found the missing jewelry in Antonio’s locker at PHIMCO, consistent with Antonio’s media confession.
- A medico-legal report by Dr. Romeo Tagala Salen of the Manila Police District stated Norma’s cause of death as multiple puncture wounds and that the weapon could have been a round instrument such as an ice pick.
- Defense claims and trial procedure
- Antonio pleaded not guilty and interposed defenses of alibi and denial while alleging coercion and intimidation by police officers at various stages: isolation, threats, pointing of a gun, stripping of his son, forced movements, being shown jewelry taken from a policeman’s pocket, being photographed at his locker, being warned to keep silent, being struck in the head, and being asked to sign papers. ...(Subscriber-Only)
Issues:
- Primary issue on appeal
- Whether the Court of Appeals erred in affirming the RTC and in finding ANTONIO DACANAY Y TUMALABCAB guilty of Parricide on the basis of his extrajudicial confession, alleged by a...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)