Case Digest (G.R. No. 51770)
Facts:
The People of the Philippines v. Francisco Galit, G.R. No. L-51770, March 20, 1985, the Supreme Court En Banc, Concepcion, Jr., J., writing for the Court.The prosecution (the People) charged Francisco Galit (defendant-appellant), an ordinary construction worker, with Robbery with Homicide for the August 23, 1977 killing of 70-year-old Natividad Fernando in Montalban, Rizal. More than two weeks after the killing, local police picked up Galit on suspicion; on September 8, 1977 the case was referred to the NBI and Galit was taken to NBI custody for further investigation. On September 9, 1977, Galit executed an extra-judicial salaysay in which he purportedly admitted participation and implicated two others. He was also photographed in what investigators characterized as a reenactment.
An information was filed and trial was conducted before the Circuit Criminal Court of Pasig, Rizal (Crim. Case No. CCC-VII-2589). The trial judge found Galit guilty and, on August 11, 1978, immediately after the defense rested, imposed the death penalty and ordered indemnity and costs. The prosecution’s case relied principally on the salaysay, a neighbor-witness (Florentino Valentino) whose testimony recounted overheard statements and certain movements by the accused, the medico-legal necropsy and photographs of the victim, and the reenactment pictures. No property of the victim was recovered from Galit, there were no eyewitnesses to the crime inside the victim’s house, and no fingerprints or other physical evidence linking Galit to the scene were presented.
Galit denied participation, offered an alibi, and strongly contested the admissibility of the salaysay: he alleged that investigators physically maltreated and tortured him to compel a confession (beatings, mauling, covering his face with a rag and forcing it into a toilet bowl of human waste), that he was not...(Pro-only)
Issues:
- Was the extra-judicial salaysay and the reenactment evidence admissible as voluntary statements?
- If the salaysay is inadmissible, does the remaining evidence suffice to sustain the conviction for Robbery with Homicide?
- Did the investigating officers’ conduct constitute maltreatment punishable under law and warrant referral for adm...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)