Case Summary (G.R. No. 147786)
Factual Background
Keyser Plastics shared premises with Greatmore Corporation, separated by a partial hollow-block and partial lauanit wall containing viewing holes. On March 22, 1998, security guard Romualdo Campos observed respondent and later heard loud noises. At noon, respondent appeared through a hole, calmly declared he had killed Keyser, and sought help to dispose of the body.
Arrest and Crime-Scene Evidence
Police secured entry keys from respondent, who surrendered without resistance. Officers found Keyser’s dismembered torso, limbs in boxes, and head in a cement bag. Respondent admitted bashing Keyser’s head with wood and sawing the corpse, then handed over a bloodstained piece of coconut lumber and a saw. Crime-scene photographs were taken.
Medical and Forensic Findings
NBI medico-legal officer Dr. Ravell R. Baluyot autopsied the remains, noting thirteen head contusions caused by a blunt object and irregular tissue edges indicating sawing. He could not exclude the possibility the victim was alive during mutilation. PNP pathologist Dr. Olga Bausa confirmed human blood on the recovered implements.
Extrajudicial Admissions and Media Interviews
Respondent gave two televised interviews to ABS-CBN and GMA reporters, voluntarily admitting the crime, describing how he struck and dismembered Keyser, and citing maltreatment and unpaid wages as motive. He expressed no remorse on camera.
Defense Version and Court’s Assessment
Respondent denied culpability, alleging police frame-up and coercion, claiming he was handcuffed by armed individuals, forced to confess, and coached before media interviews. The trial court found his story unworthy of belief and credited the prosecution’s evidence.
Admissibility of Custodial Confession
The court held respondent’s confession at the police station inadmissible under Art. III, Sec. 12 of the 1987 Constitution, as no written waiver or counsel was provided and the posted rights were read but not effectively communicated.
Spontaneous Statements as Res Gestae
The Supreme Court ruled that respondent’s immediate admission to security guard Campos and voluntary media confessions were spontaneous, not elicited by police interrogation, and thus admissible as part of the res gestae exception to the hearsay rule.
Qualification of the Offense: Treachery and Premeditation
The element of treachery was not proven beyond reasonable doubt because no eyewitness established that Keyser had no chance to defend himself or that respondent deliberately adopted a method ensuring no defense. Evident premeditation was likewise not sufficiently shown.
Outraging the Corpse as Qualifying Circumstance
The dismemberment of Keyser’s corpse constituted “outraging or scoffing at the corpse” under RPC Art. 248
Case Syllabus (G.R. No. 147786)
Facts
- Victor Francisco Keyser was owner and manager of Keyser Plastic Manufacturing Corp. in Antipolo City, sharing a building with Greatmore Corporation separated by a partial concrete‐block and partial lawanit board wall with two viewing holes.
- On March 22, 1998, security guard Romualdo Campos observed appellant Eric Guillermo enter Keyser Plastics, saw Keyser arrive, heard loud noises around 10:00 a.m., then at noon saw Guillermo look through a hole and admit he had killed Keyser and needed help to dispose of the body.
- Campos called the police; a PNP team arrived, obtained the gate keys from Guillermo, and found him shirtless, surrendering. He pointed to cardboard boxes holding Keyser’s dismembered limbs and torso; the head was in a cement bag.
- Guillermo admitted bashing Keyser with a piece of wood and dismembering the body with a saw, then mopping up the blood. He turned over the bloody piece of coconut lumber and a carpenter’s saw.
- Photographs of the scene, corpse, and implements were taken. Guillermo stated Keyser had maltreated him and co-employees and showed no remorse.
- Police brought Guillermo to the station, “informed” him of rights by having him read a poster on the wall, questioned him without counsel, and obtained an unwritten confession.
- NBI medico-legal officer Dr. Baluyot’s autopsy: body cut into seven pieces, thirteen blunt-force injuries to the head consistent with a hard blunt object; cause of death was traumatic head injury; saw marks consistent with sharp-edged instrument; possibly victim was dead when sawn but could not exclude the contrary.
- PNP Crime Lab pathologist Dr. Bausa confirmed human blood on the wood and saw but could not match blood type.
- TV reporters from ABS-CBN and GMA separately interviewed Guillermo in custody; he freely admitted the killing, described the attack and dismemberment, and expressed no regret.
Procedural History
- Information filed March 23, 1998, charging murder with treachery and evident premeditation.
- Appellant pleaded guilty April 3, 1998; moved to withdraw plea April 23, re-