Title
People vs. Butler
Case
G.R. No. L-50276
Decision Date
Jan 27, 1983
An American serviceman in the Philippines was convicted of murder for killing a woman using a porcelain statue, with evidence including fingerprints, a confession, and posthumous abuse. The court upheld the conviction but granted release due to his minority and rehabilitation.

Case Summary (G.R. No. L-50276)

Petitioner and Respondent

Plaintiff-Appellee: The People of the Philippines.
Accused-Appellant / Respondent on appeal: Michael J. Butler.

Key Dates

Crime occurred: night of August 7 to early morning of August 8, 1975.
Information filed: October 16, 1975.
Trial court conviction and sentence: judgment promulgated December 3, 1976.
Supreme Court resolution admitting certified birth certificate: June 4, 1981.
Supreme Court decision (majority and dissent issued): January 27, 1983.

Applicable Law and Constitutional Framework

Constitutional framework applicable to this 1983 decision: the constitution in force at the time (the decision predated adoption of the 1987 Constitution). Referenced statutory law and doctrines: Revised Penal Code provisions on murder and degree-of-penalty adjustments (including Article 248 and Article 68 as discussed in the opinion); Presidential Decree No. 603 (Child and Youth Welfare Code), particularly Articles 189 and 192 (as originally enacted) and the later amendment by P.D. 1179; rules and doctrine concerning admissibility of custodial statements (Miranda principles), as debated in the record and opinion.

Factual Narrative

Butler was seen with the victim on the night in question at a restaurant in Olongapo. The victim later went home with Butler. A housemaid testified that the two entered the victim’s bedroom; the victim later wrote down Butler’s name and naval identification. The following early morning the maid found the victim lying face down on the bed, partly disrobed, with a broken figurine beside her head. Police and medico-legal officers responded. A piece of cellophane wrapping from the broken figurine yielded latent prints, one of which matched Butler’s left middle fingerprint on thirteen points. NISRA agents located Butler aboard USS Hancock, informed him he was a suspect, advised him of rights, brought him to their office, and obtained a three-page written statement (Exhibit H) signed and initialed by Butler. The medico-legal examination concluded cause of death as asphyxia due to suffocation; findings also included spermatozoa in the anal smear and partially open anal muscles with fine hairs and small blood between anal folds. The partly broken porcelain figurine was present near the victim’s head.

Evidence Adduced at Trial

  • Eyewitness identifications: three witnesses who placed Butler with the victim the night before death (maid Emelita Pasco and the victim’s friends Lilia de la Paz and Rosemarie Juarez).
  • Latent fingerprint evidence: one clear fingerprint on the cellophane found on the figurine, identified by the fingerprint technician as Butler’s.
  • Extrajudicial statement (Exhibit H): a typed three-page statement signed and initialed by Butler, containing a waiver of rights and a narrative describing alcohol consumption, sexual intercourse from the rear, an altercation over money, wrestling, striking the victim on the head with a statue, the victim falling face down, Butler leaving, and subsequent movements. The statement included an express written waiver that he understood rights and did not desire counsel.
  • Medico-legal/autopsy report (Exhibit D): cause of death as asphyxia due to suffocation; absence of skull fracture or intracranial hemorrhage; anal smear positive for spermatozoa; presence of short fine hairs in anal area and small blood near anal folds.
  • Laboratory corroboration: laboratory report confirming spermatozoa in anal smear (Exhibit B-1).
  • Testimony from NISRA investigators regarding procedures followed in locating and warning Butler and the obtaining of the written statement.

Trial Court Disposition

The trial court convicted Butler of murder qualified by abuse of superior strength, and found aggravating circumstances of treachery and outraging/scoffing at the corpse. The court imposed the death penalty and ordered indemnity of P24,000 to the heirs of the victim, plus costs. Post-judgment motions (including a motion for new trial asserting minority and requesting suspension under P.D. 603 Article 192) were denied at the trial-court level.

Issues Presented on Automatic Review

The Supreme Court consolidated the appellant’s assignments into core issues: (1) whether the trial court improperly credited prosecution witnesses; (2) admissibility and voluntariness of the extrajudicial statement (Exh. H) given custodial circumstances and Miranda-type arguments; (3) whether the facts support conviction for murder qualified by abuse of superior strength and aggravating circumstances (treachery and outraging the corpse); (4) whether abuse of superior strength and treachery were both properly appreciated; (5) reliability of the medico-legal finding that death resulted from asphyxia by suffocation and that anal intercourse occurred after death; and (6) whether the accused was entitled to the relief under Article 192, P.D. 603 (suspension of sentence and commitment of youthful offender), given his minority at the time of the offense.

Standard of Review on Credibility

The Court reiterated established jurisprudence that credibility determinations by the trial court are entitled to high deference because the trial court observed witness demeanor. The appellate court will not disturb such findings absent a showing that pertinent facts were overlooked or there is a compelling reason to doubt the trial court’s assessment. Applying that standard, the Supreme Court found no error in the trial court’s acceptance of the prosecution witnesses’ testimony and the other corroborative evidence (fingerprint, medico-legal findings).

Admissibility of the Extrajudicial Statement (Waiver and Miranda Issues)

The appellant argued that the custodial interrogation violated constitutional protections against self-incrimination and that Miranda and related safeguards were breached, rendering Exhibit H inadmissible. The Supreme Court examined the record for proof of coercion, rough handling, failure to warn, or denial of counsel. The Court found that the NISRA agents identified themselves, informed Butler that he was a suspect, advised him of rights, asked if he wished counsel (he declined), and that the written waiver and signature were executed. Testimony established that a body search and handcuffing occurred as normal procedure and that warnings were given prior to restraint; investigators testified Butler acknowledged understanding his rights and indicated he did not need counsel. The Court found no competent evidence proving moral coercion or badgering and concluded the confession was voluntary. The Court therefore rejected application of Miranda to exclude Exh. H in this case, as the record sustained a valid waiver.

Legal Standards for Abuse of Superior Strength, Treachery, and Outraging the Corpse

The Court reviewed precedents delineating abuse of superior strength: it requires proof of notable inequality of forces and that the offender took advantage of such superiority to use excessive force beyond what the victim could defend against. Treachery requires deliberate measures to ensure execution without risk to the offender and is proved by circumstances showing premeditated surprise or disabling of the victim. Outraging or scoffing at the corpse is an aggravating circumstance when the accused commits acts that mock, degrade, or outrage the dead person’s body.

Supreme Court Findings on the Nature of the Homicide and Aggravating Circumstances

  • Abuse of superior strength: The Court found this circumstance established by the marked physical disparity (Butler approximately 6 feet tall and 155 lbs; the victim about 4'11"), the manner described in the statement and corroborated by autopsy findings (striking, followed by pressure applied to mouth and nose against the mattress sufficient to cause asphyxia). The Court applied the Cabiling guidance: assessment of physical conditions, objects used, and overall incident dynamics led to the conclusion that Butler took advantage of his superior strength to accomplish the killing without risk to himself.
  • Treachery: The Court concluded treachery was not sufficiently proven. There was no eyewitness testimony establishing a calculated, surprise mode and the extrajudicial statement did not show measures taken to ensure immunity from resistance beyond the single physical assault. Medical findings did not demonstrate the kind of premeditated or stealthy incapacitation usually associated with treachery.
  • Outraging/scoffing at the corpse: The Court sustained the trial court’s finding that the aggravating circumstance of outraging the corpse was proven. The medico-legal officer’s testimony that anal intercourse occurred after death (based on partly open anus and presence of spermatozoa, and the laboratory confirmation) was accepted as establishing coitus post mortem. The Court held that such conduct amounted to an outrage against the corpse and could be considered as an aggravating circumstance even if not alleged in the Information (a generic aggravating circumstance proven at trial may be used to fix penalties).

Minority (Youthful Offender) Issue and Application of P.D. 603 Article 192

The appellant’s age at the time of the offense was established in the record (born September 4, 1957), making him seventeen years, eleven months, and four days old on August 8, 1975. Article 189 and Article 192 of P.D. 603 (as originally enacted) defined youthful offenders and allowed the court, upon finding commission of the offense, to suspend further proceedings and commit the minor to custody or care of the Department of Social Welfare (or a responsible person/institution) instead of pronouncing judgment of conviction. The trial court had refused to apply Article 192 because it found the proof of minority insufficiently authenticated and because the offense was capital. The Supreme Court disagreed. After admitting a certified copy of Butler’s birth certificate into evidence on appeal, the Supreme Court concluded the lower court erred in not applying Article 192

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