G.R. No. 194139 - Cagas vs. Commission on Elections

The case involves Miguel Lasac, who was convicted by the Court of First Instance of Oriental Mindoro of parricide for the killing of his wife, Maria Consolacion Garcia.
The conviction was based on circumstantial evidence and an affidavit of admission (Exhibit B), leading to a sentence of reclusion perpetua (life imprisonment) and an order to indemnify the heirs of the deceased in the amount of P12,000.00.
The accused’s appeal, initially misdirected to the intermediate appellate court, eventually reached the Supreme Court.

Braulio Dipasupil and Maria Consolacion Garcia had cohabited as common-law partners for approximately six months.
After separating, Consolacion married Miguel Lasac on January 19, 1980.

On March 15, 1980, Consolacion was found dead atop a large stone in the middle of a creek located 70–150 meters from the couple’s dwelling.
An autopsy revealed that the victim sustained sixteen stab, incised, and hacked wounds, suggesting a brutal attack.

Flaviano Mauro testified that a week before the incident, Miguel Lasac had threatened harm if Consolacion did not change her ways.
Rufo Garcia, the victim’s father, provided a detailed account showing that on the morning of the incident he visited the couple’s house, witnessed the accused’s suspicious behavior (including the accused leaving for the crime scene), and later noted his conduct during the search and wake.
Sgt. Justino Salagubang and Sgt. Rudy Guerra gave testimony regarding the physical evidence, such as the condition of the accused’s bolo and clothing.

The accused’s bolo was noted to be “a little wet” and had a distinct scent described as “malansa” (fishy), which the prosecution argued indicated it had been washed to remove traces of blood.
Clothing worn by the accused was also found “a bit wet” (malumigmig), which was interpreted to suggest that they had been laundered to eliminate bloodstains.
The accused explained that the bolo’s wetness could have been due to water splashes from a nearby water jar or perspiration when cutting bamboo, and that his clothes were damp due to similar circumstances.

The affidavit was executed on March 24, 1980, in which the accused admitted his guilt.
Testimonies by police officers revealed that although the accused was informed of his right to remain silent, he was not informed that anything he said might be used against him in court nor was he assisted by counsel during the preparation of the affidavit.
The procedural deficiencies and failure to meet the constitutional requirements cast serious doubt on the voluntariness and admissibility of the confession.

The inadmissibility of the affidavit of admission due to the violation of constitutional rights under Section 20, Article IV of the 1973 Constitution.
The insufficiency of the evidence supporting the conviction based largely on circumstantial evidence.

The Solicitor General also urged the acquittal of the accused on the grounds of reasonable doubt, joining the appellant’s prayer for acquittal.

Whether the affidavit (Exhibit B) obtained from the accused was admissible given that it was secured:

Without the assistance of counsel; and
Without adequate advisement of his constitutional rights under Section 20, Article IV of the 1973 Constitution.

Whether the remaining circumstantial evidence (i.e., the accused’s behavior and the physical evidence such as the wet bolo and clothing) was sufficient to establish his guilt beyond reasonable doubt.
Whether the circumstantial evidence formed an unbroken chain that excludes every other rational hypothesis except the guilt of the accused.

Whether the violation in the procedure of obtaining the affidavit undermines the prosecution’s overall case, especially when the affidavit serves as the principal evidence.