Facts:
The case arose from an Information dated August 1, 2006 charging
Adrian Guting y Tomas with
Parricide for the killing of his father, Jose Guting, allegedly committed on the rainy afternoon of July 30, 2006 at Poblacion B, Camiling, Tarlac. When arraigned on September 19, 2006,
Adrian Guting y Tomas pleaded not guilty and trial ensued. Police witnesses Fidel Torre and Alexis Macusi testified that at about five o’clock on the day of the killing the accused, wet from the rain and holding a bladed weapon, approached them in front of the Camiling Police Station and spontaneously declared, “Sinaksak ko po yong tatay ko! Napatay ko na po!” PO1 Torre took the knife and turned it over to PO1 Macusi, who placed it in the police custodian cabinet; Macusi admitted he did not ask whether the knife was the weapon used or reduce the accused’s statement to writing and did not request examination of the knife because it was clean and had been exposed to rain. Police then proceeded to the victim’s house where they found Jose’s lifeless body with blood oozing from multiple stab wounds; Jose was pronounced dead on arrival at the hospital and Dr. Valentin Theodore Lomibao later testified that the victim had about thirty-nine stab wounds that caused instantaneous death. The accused offered no evidence. The Regional Trial Court, Branch 68, Camiling, convicted the accused on June 24, 2010, finding his verbal admission and circumstantial evidence sufficient to prove guilt beyond reasonable doubt and sentenced him to reclusion perpetua with awards of P50,000 as civil indemnity, P50,000 as moral damages, and P30,000 as temperate damages. The Court of Appeals in CA-G.R. CR.-H.C. No. 04596 affirmed on May 23, 2012. The accused appealed to the Supreme Court, which promulgated its decision on September 9, 2015.
Issues:
Was the accused’s uncounselled oral admission to the police inadmissible for violation of Article III, Section 12 of the 1987 Constitution? Was the conviction supported by sufficient circumstantial evidence? Did the prosecution fail to overcome the presumption of innocence?
Ruling:
Ratio:
Doctrine: