Case Digest (G.R. No. 206296)
Facts:
In People of the Philippines vs. Ramil PeAaflor y Laput (G.R. No. 206296, August 12, 2015), the Regional Trial Court (RTC) of Iligan City, Branch 5, indicted Rodolfo Omilig y Mancia, Anacleto C. Matas, Jr., Oscar Ondo, and appellant Ramil PeAaflor for the August 21, 1993 murder of Eduardo Betonio, Provincial Manager of the National Food Authority (NFA) in Lanao del Norte. The information arose amid a Commission on Audit probe led by Danilo Estur into 9,000 unaccounted rice bags under Matas’s control. On the evening of the incident, as Betonio alighted from his Ford Fiera in Palao, Iligan City, he was shot and stabbed by a knife bearing a dragon carving. His wife Vicenta heard him plead, “If you want to kill me, don’t include my wife,” then saw him collapse with the knife still embedded. Before dying on arrival at Dr. Uy Hospital, Betonio whispered “Delfin and Matas.” Forensic pathologist Dr. Livey Villarin confirmed death by cardiorespiratory arrest and hypovolemic shock due toCase Digest (G.R. No. 206296)
Facts:
- COA audit and administrative action
- In July 1993, COA State Auditor Danilo Estur discovered 9,000 bags of rice unaccounted for in the NFA bodega under the account of Anacleto Matas, Jr.
- Upon Estur’s recommendation, Eduardo Betonio, Provincial Manager of NFA Lanao del Norte, suspended Matas.
- Killing of Eduardo Betonio
- On August 21, 1993 at about 8:00 p.m., Betonio disembarked from a Ford Fiera driven by his driver Basilio Fajardo in front of his rented apartment in Palao, Iligan City. He was immediately stabbed and shot.
- Vicenta Betonio, the victim’s wife, heard her husband shout “If you want to kill me, don’t include my wife,” followed by two gunshots. She later found him alive with a dragon-carved knife in his chest; he whispered the names “Delfin and Matas” before dying.
- Dr. Livey Villarin’s post-mortem examination cited cardiorespiratory arrest and hypovolemic shock due to a penetrating stab wound and gunshot wounds as cause of death.
- Police investigation and identification of suspects
- SPO4 Antonio Lubang of Iligan City Police Department led the homicide investigation, initially naming Edgar Matas, Anacleto Matas, Jr., and Oscar Ondo as suspects.
- After publishing a sketch of the knife, police learned that Ramil PeAaflor was the actual perpetrator.
- Arrest and extrajudicial confessions of PeAaflor
- On November 12, 1993, PO1 Lubang and SPO3 Badelles invited PeAaflor from Dioscora Praquilles’s residence to the police station. PeAaflor admitted killing Betonio for ₱15,000 at Ondo’s behest.
- Same day at 3:00 p.m., Assistant City Prosecutor Albulario recorded PeAaflor’s first extrajudicial confession with court-appointed counsel Atty. Neferteri Salise-Cristobal present.
- On November 15, 1993, after briefly retaining private counsel Atty. Gerardo Padilla, PeAaflor discharged him and executed a second confession before City Prosecutor Lagcao with Atty. Floro Cavales as counsel de officio.
- Trial proceedings
- The prosecution presented 10 witnesses, including Estur, SPO4 Lubang, Dr. Villarin, Vicenta, Fajardo, and both prosecutorial counsel who assisted in the confessions.
- The defense offered eight witnesses to support co-accused alibis, challenge knife ownership, and contest the voluntariness and counsel assistance during PeAaflor’s confessions, plus two rebuttal witnesses (SPO4 Lubang, Fajardo).
Issues:
- Are PeAaflor’s extrajudicial confessions admissible despite allegations of violation of his right to competent and independent counsel under Article III, Section 12(1) of the Constitution and Section 2 of R.A. 7438?
- Whether the prosecution established corpus delicti and PeAaflor’s guilt beyond reasonable doubt for the murder of Eduardo Betonio.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)