Case Digest (G.R. No. 262579)
Facts:
People of the Philippines v. Rossano Samson y Tiongco, G.R. No. 262579, February 28, 2024, Supreme Court Third Division, Inting, J., writing for the Court.The prosecution charged Rossano Samson y Tiongco (accused‑appellant) with Murder under Article 248 of the Revised Penal Code for the October 8, 2014 killing of eleven‑year‑old Abegail Tobias y Dela Torre. The Information alleged the use of a crowbar, intent to kill, abuse of superior strength and treachery. Upon arraignment, accused‑appellant pleaded not guilty and trial on the merits followed.
The prosecution’s evidence established that on the evening of October 8, 2014 Abegail was found lifeless near her home; her clothing was disarranged and she had multiple injuries. Neighbors reported a drinking spree that day; Jeremias Dela Torre (the victim’s father) encountered accused‑appellant earlier that evening. Police investigation recovered a plastic bead from the accused’s doorstep identified as the victim’s earring pendant, and later located a crowbar at the accused’s house. The police traced the accused to his father’s home in Navotas; while being taken to the police station he allegedly admitted killing Abegail and later executed a written extrajudicial confession with the assistance of Atty. Mario M. Villegas of the Public Attorney’s Office (PAO).
Accused‑appellant denied involvement, claiming he learned of the death only later, had traveled to Navotas for rice and money, and that Atty. Villegas had him sign a document he could not read. The Regional Trial Court (Branch 18, Malolos City) rendered judgment on July 20, 2020 finding accused‑appellant guilty beyond reasonable doubt of Murder qualified by treachery and abuse of superior strength, sentencing him to reclusion perpetua without eligibility for parole and awarding civil, actual, moral and exemplary damages. The Court of Appeals, in CA‑G.R. CR HC No. 14958, affirmed the RTC decision in a Decisi...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in affirming the trial court’s admission of accused‑appellant’s extrajudicial confession?
- Did the Court of Appeals err in affirming the trial court’s conviction of accused‑appellant based on circumsta...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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