G.R. No. 147786 - People vs. Guillermo y Garcia

On March 23, 1998, appellant Eric Guillermo y Garcia was charged with the murder of his employer, Victor Francisco Keyser, committed on March 22, 1998 at Keyser Plastic Manufacturing Corp., Antipolo City, armed with a piece of wood and a saw, with intent to kill, by means of treachery and evident premeditation.
On April 3, 1998, he pleaded guilty with court‐appointed counsel; on April 23 he moved to withdraw his plea; on April 28 he was re‐arraigned, with new counsel, and pleaded not guilty.

Keyser Plastics shared a building with Greatmore Corporation, separated by a low concrete‐and‐lawanit wall with holes. Security guard Romualdo Campos saw Guillermo enter at 8:00 a.m., then heard loud noises around 10:00 a.m.
At noon, Guillermo looked through a hole and told Campos he had killed Keyser and needed help disposing of the body; Campos alerted police.
Ten minutes later, PNP officers arrived, persuaded Guillermo to surrender the gate key; inside, they found Guillermo shirtless, surrendered, and pointed to cardboard boxes containing Keyser’s dismembered remains; they recovered a bloodstained two‐foot coconut lumber and a saw.

NBI medico‐legal officer Dr. Baluyot autopsied the body sawed into seven pieces, head sustaining multiple blunt‐force injuries; cause of death: traumatic head injury; irregular soft‐tissue edges indicated use of a toothed instrument.
PNP Crime Laboratory pathologist Dr. Bausa tested the wood and saw: positive for human blood but insufficient to type.
While in custody, Guillermo was separately interviewed by ABS‐CBN’s Gusa Abelgas and GMA’s Kara David; in both interviews he calmly admitted killing Keyser, described the blows and dismemberment, and expressed no regret.

Prosecution witnesses: Campos, PNP officers, medico‐legal experts, and TV reporters. Defense: Guillermo denied guilt, claimed frame‐up, alleged false confession and lack of counsel, admitted presence in photos and discovery of remains but insisted surprise.
The RTC found the prosecution’s evidence credible, convicted Guillermo of murder, imposed the death penalty by lethal injection, and awarded damages (death indemnity ₱50,000; funeral expenses ₱50,000; compensatory ₱500,000; moral ₱500,000; exemplary ₱300,000; attorney’s fees ₱100,000 + ₱3,000 per appearance).
Under the Rules on automatic review, Guillermo appealed, assigning as errors: (a) insufficiency of evidence; (b) impropriety of death penalty; (c) excessiveness of damages.

Whether the prosecution presented sufficient and admissible evidence to prove appellant’s guilt beyond reasonable doubt.
Whether the death penalty was properly imposed for the qualifying circumstances presented.
Whether the awards of civil and moral damages, funeral expenses, compensatory and exemplary damages, and attorney’s fees were proper in amount.