G.R. No. 205412 - People vs. Guting y Tomas

Case Summary (G.R. No. 205412)

Factual Background

On the rainy afternoon of July 30, 2006, Jose Guting was found with fatal stab wounds at his residence in Poblacion B, Camiling, Tarlac; Dr. Valentin Theodore Lomibao later testified that Jose suffered 39 stab wounds causing instantaneous death. Minutes after the killing, accused-appellant approached police officers PO1 Fidel Torre and PO1 Alexis Macusi in front of the Camiling Police Station, wet from the rain and holding a bladed weapon, and declared, "Sinaksak ko po yong tatay ko! Napatay ko na po!" The knife was taken into custody by the officers who then proceeded to the victim’s home and found the lifeless body with blood still oozing; the victim was brought to the hospital and pronounced dead on arrival.

Trial Court Proceedings

An Information for Parricide under Art. 246, Revised Penal Code was filed against accused-appellant and he pleaded not guilty at arraignment. Pretrial and trial on the merits ensued before the RTC, which on June 24, 2010 convicted accused-appellant of Parricide, relying on his verbal admission and corroborating circumstantial evidence, and sentenced him to Reclusion Perpetua with awards of P50,000.00 as civil indemnity, P50,000.00 as moral damages, and P30,000.00 as temperate damages.

Evidence and Witness Testimony

PO1 Torre and PO1 Macusi testified that accused-appellant spontaneously approached them with a knife and admitted stabbing his father; PO1 Torre took the knife and gave it to PO1 Macusi, who placed it in the police custodian cabinet and later accompanied other officers to the victim’s house. PO1 Macusi conceded he did not ask whether the knife was the weapon used nor did he reduce the admission to writing, explaining that the knife appeared clean and the events unfolded rapidly. Flora Guting, the victim’s wife, testified that she was not present at the time of the killing and only learned of the incident from the police; accused-appellant presented no evidence in his defense.

Issues on Appeal

Accused-appellant raised three assignments of error to the Supreme Court, captioned in his brief as: I THE TRIAL COURT GRAVELY ERRED IN CONVICTING THE ACCUSED-APPELLANT ON THE BASIS OF HIS EXTRAJUDICIAL ADMISSION; II THE TRIAL COURT GRAVELY ERRED IN CONVICTING THE ACCUSED-APPELLANT ON THE BASIS OF INSUFFICIENT CIRCUMSTANTIAL EVIDENCE; and III THE TRIAL COURT GRAVELY ERRED IN FINDING THE ACCUSED-APPELLANT GUILTY BEYOND REASONABLE DOUBT OF THE CRIME CHARGED DESPITE THE PROSECUTION'S FAILURE TO OVERTHROW THE CONSTITUTIONAL PRESUMPTION OF INNOCENCE IN HIS FAVOR.

Supreme Court’s Assessment of the Admission

The Court examined accused-appellant’s contention that his oral confession was inadmissible under Art. III, Sec. 12, 1987 Constitution, which protects the right to counsel during custodial investigation and renders involuntary confessions inadmissible. Relying on the definition of custodial investigation in People v. Marra, the Court found that custodial interrogation commences when a person is taken into custody and singled out as a suspect and is subjected to questioning that tends to elicit an admission. The Court concluded that accused-appellant was not under custodial investigation when he made the admission because he voluntarily approached the police officers, the statement was spontaneous and not the product of interrogation, and he was taken into custody only after he had already confessed.

Analogous Authorities and Distinctions

The Court distinguished this case from People v. Cabintoy, where uncounselled extrajudicial confessions were held inadmissible because the confessions there were made while the accused were already suspects under custodial investigation. The Court found the present facts analogous to People v. Andan, in which an uncounselled confession to a public official was admitted because it was spontaneous, not elicited by interrogation, and the declarant sought out the official of his own volition; the Court reiterated that Section 12 is aimed at preventing compulsory or coercive elicitation, not voluntary admissions.

Res Gestae and Admissibility

The Court applied Rule 130, Sec. 26, Rules of Court, and the doctrine of res gestae, holding that accused-appellant’s declaration was admissible as part of the res gestae because it satisfied the three requisites: the principal act was a startling occurrence, the statement was made before the declarant had time to contrive, and the statement concerned the occurrence and its immediately attending circumstances. The circumstances showed that accused-appellant immediately sought the police while still wet from the rain and clutching the knife and that the body displayed fresh wounds, which corroborated the spontaneity and contemporaneity of the admission.

Circumstantial Evidence and Conviction

The Court further held that circumstantial evidence corroborated the admission and satisfied Rule 133, Sec. 4, Rules of Court, which requires more than one circumstance, proof of the facts from which inferences are drawn, and a combination of circumstances producing conviction beyond reasonable doubt. The RTC had found that accused-appellant’s prompt surrender with the weapon, his failure to explain or comfort the grieving mother, and his non-resistance to detention formed an unbroken chain pointing solely to him as the perpetrator. The Supreme Court accorded respect to the RTC’s credibility findings and found the circumstantial proof sufficient to support conviction.

Elements of Parricide and Penalty

The Court reiterated the elements of Parricide under Art. 246, Revised Penal Code: that a person was killed, that the deceased was killed by the accused, and that the victim bore the specified familial relationship to the accused. The Court found these elements established by the autopsy and by documentary proof of lineage, noting the accused’s bi

Case Syllabus (G.R. No. 205412)

Parties and Procedural Posture

PEOPLE OF THE PHILIPPINES prosecuted the case for Parricide before the Regional Trial Court, Camiling, Tarlac, Branch 68.
ADRIAN GUTING Y TOMAS, designated in the record as the accused-appellant, was charged in an Information with Parricide under Article 246 of the Revised Penal Code.
The RTC promulgated a Decision dated June 24, 2010 finding accused-appellant guilty and imposing criminal and civil liabilities.
The accused-appellant appealed to the Court of Appeals in CA-G.R. CR.-H.C. No. 04596, which affirmed by Decision dated May 23, 2012.
The accused-appellant filed the present appeal to the Supreme Court, which considered the appeal through its First Division.

Key Factual Allegations

The Information alleged that on the rainy afternoon of July 30, 2006, accused-appellant stabbed his father, Jose Guting, several times inside their residence, causing instantaneous death.
Police testimony recounted that accused-appellant appeared at the Camiling Police Station, wet from the rain and holding a bladed weapon, and declared that he had stabbed his father.
Police officers took custody of the bladed weapon from accused-appellant and later found the victim’s lifeless body with blood still oozing from stab wounds.
The victim, Jose, was transported to the hospital and was pronounced dead on arrival.

Trial Evidence

PO1 Fidel Torre and PO1 Alexis Macusi testified that accused-appellant spontaneously approached them at the police station and proclaimed, "Sinaksak ko po yong tatay ko! Napatay ko na po!" and surrendered a knife.
Flora Guting, the victim’s wife, testified that she learned of the incident from police officers and that Jose earned about P200.00 a day as a tricycle driver.
Dr. Valentin Theodore Lomibao performed the autopsy and testified that the victim suffered approximately thirty-nine stab wounds that caused instantaneous death.
Accused-appellant opted not to present evidence in his defense.

Issues Presented

Whether the trial court erred in convicting accused-appellant chiefly on the basis of his extrajudicial admission in violation of Art. III, Sec. 12, 1987 Constitution.
Whether the conviction could be sustained on the basis of the circumstantial evidence presented.
Whether the prosecution overcame the constitutional presumption of innocence.

Admissibility of the Confession

The Court addressed the constitutional protection in Article III, Section 12, 1987 Constitution, which guarantees the right to be informed of the right to counsel during custodial investigation and renders involuntary confessions inadmissible.
The Court explained that custodial investigation begins when a person is taken into custody and is singled out as a suspect and the police begin questioning that tends to elicit an admission.
The Court found that