Title
Domingo vs. De Guzman III vs. People
Case
G.R. No. 255100
Decision Date
Feb 26, 2024
The consolidated cases involve petitions for review concerning the roles of Domingo De Guzman and Dalia Pastor in the murder of Enzo Pastor, with the Court of Appeals dismissing De Guzman's appeals and ruling in favor of Dalia due to lack of probable cause.
parricide
murder
criminal conspiracy
A

Case Summary (G.R. No. 255100)

Factual background — the shooting and immediate identification evidence

On June 12, 2014, Enzo Pastor was ambushed while driving a truck and died of gunshot wounds; his companion Paolo Salazar survived and testified he saw the assailant’s uncovered nose, eyes and forehead despite a motorcycle mask and helmet and later identified PO2 Angel after media exposure. The prosecution’s factual narrative rests on PO2 Angel’s extrajudicial admissions (including a televised interview) that he shot Enzo and that De Guzman engaged him; the existence of meetings, photographs, monetary offers, a provided motorcycle and firearm, and telephone contacts among the principal actors are detailed in the investigative attachments and witness proofs.

Prosecution theory and corroborating testimonies

The prosecution relied primarily on: (a) PO2 Angel’s extrajudicial statements and a public televised interview in which he admitted killing Enzo and implicated De Guzman as mastermind and Dalia as present/connected to the plan; (b) the testimony and sworn statement of Alvin Nidua (a self-proclaimed gun‑for‑hire) that he met De Guzman and Dalia at a meeting where a picture of Enzo and cash were presented and an offer was discussed; (c) an entrapment operation of August 26, 2014 where De Guzman allegedly handed money to PO2 Angel and was arrested with firearms and cash; (d) the househelp Domen’s affidavit identifying De Guzman as Dalia’s alleged lover and describing marital strife; and (e) phone logs and other documentary evidence indicating communications among the actors on relevant dates.

Defense contentions and challenges to admissibility and arrest legality

Defendants disputed the weight and admissibility of the extrajudicial confession(s). PO2 Angel later recanted, alleging coercion and an illegal drug arrest; De Guzman challenged his warrantless arrest and the admissibility of items seized, pointing to CCTV footage and asserting no opportunity was afforded him to hand money to PO2 Angel. Dalia asserted lack of probable cause and alleged forum shopping and did not file a counter‑affidavit during the preliminary investigation. The defenses invoked res inter alios acta (that one person’s extrajudicial confession should not be conclusive against another), alleged police coercion, and claimed insufficiency of direct evidentiary links to Dalia.

Relevant trial-court rulings and outcome on bail and warrants

Regional Trial Court Branch 85 issued omnibus orders consolidating informations and admitting a substituted information that named De Guzman as co-accused; it denied motions to dismiss and denied bail for De Guzman and PO2 Angel on the ground that the evidence of guilt was strong, referencing testimony of Salazar, Nidua, Atty. Lumantao (who assisted PO2 Angel during his custodial interview), PO2 Langa (investigator/arresting officer), and others. Branch 91 issued an earlier order directing a warrant of arrest for Dalia and a hold‑departure order, which became the subject of separate review petitions.

Court of Appeals disposition and its reasons

The Court of Appeals consolidated the petitions. It granted Dalia’s petition for certiorari and dismissed Criminal Case No. R‑QZN‑15‑01870‑CR for parricide for lack of probable cause, annulling the Branch 91 warrant of arrest and recalling the hold‑departure order. The CA reasoned that PO2 Angel did not definitely identify Dalia as mastermind or active conspirator and that being present or in communication was insufficient to establish conspiracy without an overt act in furtherance of the plot. Conversely, the CA denied De Guzman’s petitions and sustained the trial court’s findings as to probable cause and the denial of bail, finding interlocking circumstantial evidence and corroboration (including Nidua and other witnesses) sufficient to sustain probable cause and to justify denial of bail.

Issues presented to the Supreme Court on reviewability and merits

The Supreme Court was called upon to determine: (1) whether it may review the uniform factual findings of the trial court and the Court of Appeals under a Rule 45 petition (De Guzman’s claim), and (2) whether the appellate court erred in dismissing the indictment against Dalia for lack of probable cause while sustaining probable cause against De Guzman (Tomas and the People’s petitions). The petitions raised mixed questions about reviewability of factual findings, the sufficiency of probable cause, admissibility and weight of extrajudicial confessions and media admissions, and the proper disposition of bail applications.

Legal standards applied by the Supreme Court (reviewability, probable cause, bail)

The Court reiterated that Rule 45 of the Rules of Court confines a petition for review on certiorari to questions of law; assessment and weighing of evidence are generally factual matters that the Supreme Court will not re‑examine except under enumerated exceptions (e.g., findings grounded on speculation, grave abuse of discretion, conflicts of findings, findings contrary to admissions or specific undisputed facts, conclusions unsupported by citation of evidence, among others as listed on the record). On probable cause and warrants, the Court applied the Constitutionally mandated personal determination requirement by the judge and the established standard that probable cause is a less stringent calculus than proof beyond reasonable doubt — it suffices that facts and circumstances would lead a reasonably prudent person to believe an offense was committed by the person sought to be arrested. On bail the Court applied Article III, Section 13 of the 1987 Constitution and Rule 114: where a capital offense (or offense punishable by reclusion perpetua) is charged, bail is not available if evidence of guilt is strong; the prosecution bears the burden to show that the evidence of guilt is strong at the bail hearing and the standard is one of “evident proof” or “great presumption” of guilt as articulated in People v. Cabral and related authorities cited in the record.

Supreme Court analysis and ruling as to De Guzman (probable cause review and bail)

The Supreme Court declined to disturb the concurrent factual findings of the trial and appellate courts because no exceptional ground for review existed. Applying the applicable standards, the Court concluded that the record contained sufficient, interlocking evidence to establish probable cause against De Guzman as an alleged mastermind and to support denial of bail. The Court emphasized: (a) PO2 Angel’s contemporaneous televised admission to news anchor Noli De Castro — admissible as a public/confessional admission not shown to be extracted under custodial coercion; (b) Nidua’s statement and testimony that he was approached by De Guzman and Dalia to carry out the killing and that Dalia presented a picture and cash, corroborating motive and plan; (c) the entrapment operation and arrest of De Guzman while allegedly handing money to PO2 Angel and the seizure of firearms and cash; (d) identifying evidence by Domen that De Guzman was Dalia’s alleged lover and motive to eliminate Enzo; and (e) phone logs and other circumstantial indicia. The Court held that even if PO2 Angel’s custodial confession were excluded, the remaining evidence (including the media admission and Nidua’s testimony) produced a strong showing of guilt for purposes of probable cause and of the “evidence of guilt is strong” standard at bail hearings. The Court accordingly denied De Guzman’s petition for c

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