Case Digest (G.R. No. 144656)
Case Digest (G.R. No. 144656)
Facts:
The People of the Philippines v. Gerrico Vallejo y Samartino @ Puke, G.R. No. 144656, May 09, 2002, the Supreme Court En Banc, Per Curiam. The plaintiff-appellee is the People of the Philippines; the accused-appellant is Gerrico Vallejo y Samartino (also called “Puke”), prosecuted for Rape with Homicide. The Regional Trial Court (RTC), Branch 88, Cavite City (Judge Christopher O. Lock) convicted Vallejo and on July 31, 2000 sentenced him to death and ordered civil and moral indemnities. Vallejo appealed to the Supreme Court.On July 10, 1999, nine-year-old Daisy Diolola went to a neighbor’s house for tutoring where Vallejo was staying. Several witnesses placed Daisy and Vallejo together that afternoon; later witnesses saw Vallejo with wet clothes and uneasy. Daisy’s body was found tied to a tree by the river; autopsy showed manual strangulation, traumatic injuries consistent with sexual assault, and vaginal lacerations. Police recovered bloodstained clothing from Vallejo’s home (a white shirt and violet shorts) which the NBI tested as positive for human blood type A; Vallejo’s blood type was O. Vaginal swabs from the victim contained DNA profiles matching Vallejo.
During investigation Vallejo made oral admissions to the municipal mayor and to an NBI forensic biologist, and executed a written extrajudicial confession before the inquest prosecutor; he was advised and assisted at different times by Atty. Lupo Leyva and later by a Public Attorney’s Office lawyer, Atty. Sikat Agbunag. At trial the prosecution presented ten witnesses (including the victim’s mother, medico-legal officer, NBI forensic experts, mayor, and neighbors) and introduced forensic and DNA evidence; the defense put Vallejo and his sister on the stand, who claimed alibi and that confessions were coerced.
The RTC found the aggregate of circumstantial and forensic evidence and Vallejo’s confessions sufficient to prove guilt beyond reasonable doubt and imposed the death penalty (with indemnities). Vallejo appealed to the Supreme Court asserting (1) insufficiency/weakness of circumstantial evidence, (2) oral confessions were hearsay and inadmissible, and (3) the extrajudicial written confession was obtained by force/intimidation and that counsel during custodial investigation was ineffective.
Issues:
- Was the circumstantial and forensic evidence sufficient to convict the accused beyond reasonable doubt?
- Were the oral admissions made to the mayor and to the NBI forensic biologist admissible?
- Was the written extrajudicial confession admissible, or was it involuntary/tainted by coercion and ineffective assistance of counsel?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)