Title
People vs. Mantes
Case
G.R. No. 117166-67
Decision Date
Dec 3, 1998
Husband and friends acquitted of wife's murder due to inadmissible confessions, hearsay evidence, and insufficient proof of guilt beyond reasonable doubt.

Case Digest (G.R. No. 117166-67)
Expanded Legal Reasoning Model

Facts:

  • Overview of the Case
    • The case is an appeal from the decision of the Regional Trial Court, Branch 73, Antipolo, Rizal.
    • The accused-appellant Domingo Francisco was found guilty of parricide for killing his legally wedded wife, Erliste Arcilla Francisco.
    • Co-accused-appellants Randy Mantes, Jerome Garcia, and Jovy Velasco were convicted of murder for their participation in the killing.
    • All accused-appellants were sentenced to reclusion perpetua and ordered to indemnify the victim’s heirs in the amount of P50,000.00, plus the costs of the suit.
  • Chronology and Circumstances of the Crime
    • On February 28, 1992, Erliste Arcilla Francisco disappeared; she was last seen with Domingo Francisco at the UERM Hospital where he worked as a janitor.
    • The following day, on February 29, 1992, a severely burned female cadaver was discovered at Barangay Cupang, Antipolo, Rizal.
    • The body, unrecognizable due to extensive burning, was later identified by personal effects and by family members (though this identification is later challenged).
  • Investigation and Arrest
    • Police investigations commenced after Erliste’s disappearance and the burning of the cadaver.
    • The victim’s mother, Dominga Arcilla, along with another witness, Alice Francisco, provided information leading to the arrest of Domingo Francisco on March 5, 1992.
    • CCTV or eyewitness testimonies were notably absent; the case primarily rested on identifications and statements made by involved witnesses under questioning.
  • Details of the Charges and Alleged Acts
    • The information filed on March 6, 1992, charged Domingo Francisco with parricide on the basis that he conspired with his friends to kill his wife.
    • The other three accused were charged with murder, with allegations that they used superior strength and designated means (e.g., striking with a softdrink bottle, strangling with wire) during the commission of the crime.
    • The charges indicated premeditation, concerted action, and noted that the crime was executed with evident deliberation.
  • Key Testimonies and Evidence Presented by the Prosecution
    • Police Testimonies
      • SPO1 Gil A. Colcol testified that Domingo Francisco admitted guilt and implicated the other accused during a custodial investigation.
      • Other police officers (SPO1 Jaime Tarasona and SPO3 Medardo Sumait) corroborated the investigative narrative and the purported confessions of the accused.
      • It was noted that the confessions were given orally, without the presence or assistance of counsel, and were not reduced to writing.
    • Witness Testimonies
      • Neighbors Maria Vda. de Tawat and Rachel Loyola presented accounts indicating a troubled marital relationship, with Erliste frequently complaining about Domingo Francisco’s extra-marital affair and abusive behavior.
      • Testimonies also established a possible motive—that Erliste’s complaints and conflicts over a paramour might have driven Domingo Francisco to commit the crime.
      • Other witnesses, such as Barangay Captain Dominador Baniega and a tire vulcanizer Arsenio del Socorro, testified as to disputes between the couple and indications of domestic strife.
    • Medical and Forensic Evidence
      • Dr. Dario Gajardo, the medical examiner, noted the presence of multiple lacerated wounds, a ligature mark, and third degree burns on the cadaver.
      • The time frame for death was estimated based on the post-mortem examination conducted on February 29, 1992.
      • Identification of the victim’s remains relied on personal effects (e.g., dentures, earrings, a wrist watch, and a ring), though the method and reliability of this identification were later questioned.
  • Defense and Rebuttal Evidence
    • Accused-appellant Domingo Francisco testified in his own defense, denying that he had killed his wife.
    • He claimed that in the past, Erliste had often left the house and that he had even actively searched for her on the day of her disappearance.
    • Domingo Francisco denied having a paramour and disputed the assertion that he betrayed his own marital commitment or admitted any culpability to any neighbor or police officer.
    • His testimony also highlighted that the confessions attributed to him and his co-accused were either vague or inconsistent with his personal account.
  • The Trial Court’s Findings
    • The trial court placed significant reliance on the prosecution’s presentation of nine witnesses.
    • It found the motive for the killing by Domingo Francisco to be clearly established through his alleged admissions and the circumstantial evidence of marital discord.
    • The identification of the cadaver and the oral confessions, despite being given without counsel and not documented in writing, were deemed sufficient by the trial court to convict the accused.
    • The decision made on June 16, 1994, upheld the convictions and reclusion perpetua penalties as imposed on all accused-appellants.

Issues:

  • Admissibility of Uncounselled Oral Confessions
    • Whether the admissions allegedly made by the accused under custodial investigation were valid, given they were:
      • Not in writing.
      • Made without the assistance of counsel.
    • Whether the violation of Article III, Section 12 of the Constitution renders such confessions inadmissible.
  • Sufficiency of Evidence in Proving Corpus Delicti
    • Whether the evidence presented was sufficient to prove the corpus delicti of the crime.
    • Challenges on the identification of the burnt cadaver:
      • The cadaver’s identification was based on hearsay.
      • The reliance on testimonies from persons not presented in court (e.g., family members or unidentified witnesses).
  • Reliance on Motive and Circumstantial Evidence
    • Whether the proof of motive alone can substitute the lack of direct evidence or proper confession.
    • Whether establishing motive through testimonies from neighbors and relatives is enough to overcome the presumption of innocence.
  • Procedural and Constitutional Violations
    • Whether the absence of counsel during the police investigations and confessional statements constituted a violation of the accused’s constitutional rights.
    • The effect that such procedural deficiencies may have on the overall guilt determination of the accused-appellants.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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