Case Digest (G.R. No. 133026)
Facts:
People of the Philippines v. Edward Endino (At Large) and Gerry Galgarin alias Toto, G.R. No. 133026, February 20, 2001, Supreme Court Second Division, Bellosillo, J., writing for the Court. The plaintiff-appellee is the People of the Philippines; the accused are Edward Endino (at large) and Gerry Galgarin alias Toto, the latter appearing as accused-appellant.On the evening of 16 October 1991 in Puerto Princesa City, Gerry Galgarin suddenly approached the victim Dennis Aquino and stabbed him repeatedly while Aquino stood with his girlfriend Clara Agagas; as Aquino attempted to flee toward Midtown Sales, Edward Endino appeared and fired at Aquino. Aquino collapsed inside the Elohim Store, was taken to the hospital, and died; the autopsy attributed death to a penetrating stab wound to the heart causing hypovolemic shock and cardio-respiratory arrest.
An Information for murder was filed on 18 October 1991 against Endino and Galgarin; warrants issued but both remained at large and, on 26 December 1991, the trial court (Regional Trial Court, Branch 49, Puerto Princesa City, Decision penned by Judge Panfilo S. Salva) ordered the case archived without prejudice to reinstatement upon apprehension. Gerry Galgarin was arrested on 19 November 1992 in Antipolo and, the following day, was escorted by Palawan police toward Palawan; en route they stopped at ABS-CBN where Galgarin was interviewed on television and, on camera, admitted stabbing Aquino and identified Endino as the shooter.
At trial, prosecution witnesses — notably Clara Agagas, neighbor Anita Leong, and Josephine Leong (a child who said she saw Galgarin stab Aquino and recalled a mole below his nose) — identified Galgarin as the assailant. Galgarin advanced an alibi that he was in Antipolo on 14–16 October 1991 assisting his common-law wife with childbirth; a midwife, Clarita Pedragoza, and co-workers offered varying corroboration, but the midwife admitted registering the child's birth over two years later and other testimony did not establish Galgarin's presence in Antipolo on the evening of 16 October. Galgarin disowned his televised confession, claiming it was coerced by police and thus inadmissible under Section 12, Article III of the 1987 Constitution.
The trial court admitted the videotaped interview, finding no coercion and observing that the confession was made openly before newsmen; it rejected the alibi and convicted Galgarin of murder qualified by treachery, sentencing him to reclusion perpetua a...(Subscriber-Only)
Issues:
- Was the videotaped television confession admitted against accused-appellant Gerry Galgarin admissible under the Constitution and the exclusionary rule?
- Whether the evidence was sufficient to prove that Gerry Galgarin committed murder qualified by treachery and whether his alibi shoul...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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