Case Summary (G.R. No. 72566)
Charges and Initial Conviction
Miguel Lasac was convicted of parricide in 1981 by the trial court, receiving a sentence of life imprisonment and an order to indemnify the heirs of Maria Consolacion Garcia in the sum of P12,000. The conviction was based primarily on circumstantial evidence and an affidavit that Lasac allegedly executed, admitting guilt.
Legal Proceedings and Appeals
Lasac's appeal was erroneously sent to the Intermediate Appellate Court but ultimately reached the Supreme Court. He contested his conviction, arguing several points. He contended that his affidavit was inadmissibly obtained, claiming it was prepared without legal counsel and through coercive means. Furthermore, he asserted that the conviction relied solely on circumstantial evidence.
Circumstantial Evidence Presented
Key evidence against Lasac included testimonies from witnesses indicating suspicious behavior. Notably, a witness recounted Lasac's ominous statement to the effect that harm could come to Consolacion if she did not change her ways. Additional circumstantial evidence involved inconsistencies in Lasac's account of the events leading to Karen's disappearance, and observations of his behavior post-incident, such as drinking excessive water and lacking visible remorse.
Affidavit of Admission
The prosecution's case heavily relied on the affidavit Lasac allegedly signed, which contained a confession. However, the Supreme Court raised serious concerns regarding the admissibility of this affidavit, highlighting violations of the 1973 Constitution, specifically the right to counsel. It was noted that Lasac was not adequately informed of his rights and did not have legal representation when signing the affidavit.
Analysis of Constitutional Violations
The Court determined that Lasac's affidavit was rendered inadmissible due to procedural failures in advising him of his rights, a constitutional requirement under the 1973 Constitution's Section 20, Article IV. The Court cited prior rulings underscoring the necessity of counsel during confessions, establishing that any waiver of this right must be informed and unequivocal.
Inconsistencies in Evidence
Upon examining the circumstantial evidence presented, the Supreme Court found that the evidence was insufficient to uphold the conviction of Lasac. The circumstantial evidence failed to exclude other reasonable hypotheses,
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Case Overview
- The case involves Miguel Lasac, who was found guilty of parricide for the murder of his wife, Maria Consolacion Garcia.
- The trial court sentenced him to life imprisonment and ordered him to indemnify the heirs of the deceased in the amount of P12,000.00.
- Lasac's appeal to the Supreme Court was based on alleged errors made by the lower court.
Grounds for Appeal
- Lasac presented several assignments of errors:
- Admission of Affidavit: He contended that the lower court erred in convicting him based on his affidavit (Exhibit B) due to:
- Lack of legal counsel during the affidavit's execution.
- Failure of the administering officer (Judge Zacarias Garcia) to inform him of his constitutional rights.
- Coercion and intimidation leading to the signing of the affidavit.
- The affidavit was allegedly secured through threats, including the use of a gun.
- Circumstantial Evidence: He argued that the conviction was based solely on circumstantial evidence, which he claimed was insufficient to support a guilty verdict.
- Admission of Affidavit: He contended that the lower court erred in convicting him based on his affidavit (Exhibit B) due to:
Factual Background
- Maria Consolacion Garcia was previously in a common-law relationship with Braulio Dipasupil before marrying Miguel Lasac on January 19, 1980.
- On March 15, 1980, Consolacion was found dead with multiple stab wounds near their home.
- The police investigation