Case Summary (G.R. No. 152398)
Key Dates
Offense: February 14, 1989
Information filed: October 19, 1993
Sandiganbayan decision: November 28, 2000
Motion for reconsideration denied: January 14, 2002
Supreme Court decision: April 14, 2005
Applicable Law
1987 Constitution (effective at time of Supreme Court decision).
Presidential Decree No. 1606, as amended by PD 1861 (jurisdiction of Sandiganbayan).
Revised Rules of Criminal Procedure (Rule 65 for certiorari).
Revised Rules of Evidence (Rule 133 on circumstantial evidence).
Revised Penal Code (Articles on murder penalty and Indeterminate Sentence Law).
Charge
Crisostomo was charged with murder under an Information alleging that, taking advantage of his position as jail guard, he conspired with six inmates to inflict fatal injuries on Renato Suba inside his cell, then staged the death as suicide.
Arraignment and Plea
On December 15, 1993, Crisostomo pleaded not guilty. Trial proceeded with the State presenting witnesses, then Calingayan testifying for the defense.
Prosecution’s Case
• Witnesses established Suba’s good health before detention and absence of external access to the cells during relevant times.
• Autopsy and exhumation reports showed massive internal injuries (ruptured liver, torn mesentery, torn stomach) incompatible with hanging or self-infliction.
• NBI report concluded multiple assailants inflicted deliberate fatal injuries and that only the jail guard held keys to cell access.
• Discrepancies arose between detainee lists and police blotter regarding number of prisoners.
Defense’s Case
• Calingayan denied involvement and testified that all cell doors were habitually left open by inmates, not by the guard.
• He last saw Suba alive around 6 p.m., discovered Suba’s body hanging from a thin blanket, and denied any fresh admissions to the jail.
• He described cell layout: four cells in a row, separated by cement partitions, common door locked by guard, comfort room in a separate open cell.
Sandiganbayan Decision
The Sandiganbayan found jurisdiction proper under PD 1606, convicted Crisostomo and Calingayan of murder, and sentenced Crisostomo to prision mayor (12 y 5 m 11 d) as minimum to reclusion temporal (18 y 8 m 1 d) as maximum. Warrants issued for other at-large co-accused.
Issues Raised
- Whether Sandiganbayan had jurisdiction over Crisostomo, a police officer charged with murder.
- Whether guilt was proven beyond reasonable doubt despite no direct evidence of Crisostomo’s participation.
Jurisdictional Analysis
• Under PD 1606, sec. 4(a)(2), Sandiganbayan has exclusive original jurisdiction over offenses by public officers in relation to their office punishable by over six years.
• The Information alleged killing of a detention prisoner—an act intimately connected to the jailer’s duties to safeguard inmates.
• People v. Montejo exception recognizes that a public officer’s criminal act committed while performing the functions of office, even improperly, is within Sandiganbayan’s jurisdiction.
• The Supreme Court held the charge sufficiently alleged nexus with official duties, and in any event the Ombudsman’s resolution supported transfer under Republic v. Asuncion procedures.
Lack of Proof Beyond Reasonable Doubt
• No direct evidence tied Crisostomo to the assault.
• Circumstantial evidence must (a) consist of multiple proven facts, (b) permit only one inference, (c) establish guilt beyond reasonable doubt.
• The autopsy proved deliberate homicide, but did not link Crisostomo’s actions or omissions to a conspiracy or the assault itself.
Conspiracy Requirement Not Met
• Conspiracy demands proof of a prior common design by clear and convincing evidence. Joint action alone is insufficient.
• Three circumstances cited—control of keys, guard’s theoretical ability to hear/see the assault, record discrepancies—did not exclude alternative explanations (negligence or inmate-initiated violence).
• Cell layout, habitual open doors, poor lighting and partitions made guard’s actual observation implausible.
• Discrepancies in lists without explanation do not prove pa
Case Syllabus (G.R. No. 152398)
Case Background
- G.R. No. 152398, decided April 14, 2005, First Division, authored by Justice Carpio
- Appeal by certiorari under Rule 65 challenging Sandiganbayan’s denials of petitioner’s motions for reconsideration
- Lower court Decision (November 28, 2000) found SPO1 Edgar Crisostomo guilty of murder, sentencing him under the Indeterminate Sentence Law to 12 years, 5 months, 11 days (minimum) to 18 years, 8 months, 1 day (maximum)
Charge in the Information
- Date of filing: October 19, 1993
- Accused: SPO1 Edgar T. Crisostomo (jail guard of Solano Municipal Jail) and six inmate co-accused
- Victim: Renato Suba, a detention prisoner at Solano Municipal Jail
- Allegations: conspiracy, treachery, superior strength, use of rough-surfaced instruments and fist blows, inflicting internal injuries (liver, mesentery, stomach) resulting in death
- Legal basis: Murder (use of means to insure impunity), “contrary to law”
Arraignment and Plea
- Date: December 15, 1993
- Crisostomo, assisted by counsel, pleaded not guilty
- Trial proceeded thereafter
Prosecution’s Version of Events
- February 13, 1989: Renato Suba detained for alleged assault
- February 14, 1989, 5:00 p.m.: Brother Rizalino visits, finds Renato in good health
- February 14, 1989, 9:10 p.m.: Renato found dead outside his cell by Rizalino
- Jail layout: four adjacent cells with individual grill doors (usually left open), one padlocked common door, single guard on duty (Crisostomo) holding keys
- No new admissions or movements recorded between detention and death
- Discrepancies in detainee lists and police blotter as to number of prisoners on February 14–15, 1989
- Autopsy and exhumation reports: massive internal injuries incompatible with suicide; deliberate intent to kill deduced
- Silence of guard and inmates, and Crisostomo’s later bail-jump, point to conspiracy
Defense’s Version of Events
- Crisostomo’s presentation deemed waived due to his non-appearance at scheduled hearings
- Sole defense witness: Mario Calingayan (co-accused, 16 years old at time of arrest)
- Calingayan’s testimony:
- Detained in second cell; Renato alone in third cell; all cell doors habitually open
- Last saw Renato alive between 5:00–6:00 p.m.; thereafter, played cards until about 9:00 p.m.
- Discovered Renato’s body hanging by a thin blanket from the window bars; believed suicide
- Jail compartments separated by hollow-block partitions; common toilet in fourth cell
- No grudge or prior incident between Renato and inmates; Solano police interviewed him next morning
Sandiganbayan Decision
- Only Crisostomo and Calingayan stood trial; five other accused remained a