Title
People vs. Lorenzo y Corsino
Case
G.R. No. 110107
Decision Date
Jan 26, 1995
Dolores Lorenzo, a policewoman, was convicted of parricide for killing her husband in 1990. Despite her claim that a neighbor was the killer, the court upheld her guilt based on her surrender of weapons, confession, and credible prosecution witnesses, sentencing her to reclusion perpetua.
parricide
witness testimonies
admission

Case Summary (G.R. No. 110107)

Factual Background

On the evening of July 30, 1990, Agapito Lorenzo was found mortally wounded in Barangay 12, Balzain, Tuguegarao. The deceased sustained multiple injuries shown in the record as nine chop wounds, thirteen stab wounds, and nine incised wounds, with abrasions and multiple contusions. A tricycle driver reported a stabbing incident to on-duty policeman SPO1 Jose Eclipse, who proceeded to the scene and met Policewoman Dolores Lorenzo carrying a blood-stained bolo and a fan knife.

Prosecution's Evidence at Trial

The prosecution relied principally on the testimony of SPO1 Jose Eclipse and barangay captain Isabelo Liban. Eclipse testified that he met the appellant who immediately surrendered the blood-stained bolo and fan knife and told him, “I killed my husband.” Eclipse accompanied the appellant to the Tuguegarao PNP Station and, in the appellant’s presence, reported to the desk officer that she had surrendered the weapons and had told him she killed her husband; this report was entered in the police blotter as Exhibit 1. The body of the deceased and the weapons were introduced in evidence as exhibits.

Defense Evidence and Theory at Trial

The defense presented the testimony of Dolores Lorenzo and Romeo Racheta. Their theory was that a neighbor, Robert Santos, stabbed and hacked Agapito, and that the appellant either collapsed in shock or was otherwise not the assailant. The appellant testified that she found her husband in a struggle with Robert Santos, that she fainted, and that upon regaining consciousness she discovered her husband dying and surrendered the knife and bolo to Eclipse without making any inculpatory admission at the time.

Trial Court Findings and Rationale

The trial court found the prosecution witnesses credible and accepted Eclipse’s account that the appellant surrendered the weapons and admitted to killing her husband. The court characterized the appellant’s version as a “palpably a put-up scenario” and relied on several factors: the appellant’s failure to protest or correct the police blotter entry; the absence of any contemporaneous accusation against Robert Santos; the appellant’s failure to file a counter-affidavit during preliminary investigation; inconsistencies between the appellant’s and her witness’s accounts; and the implausibility of her explanation that an already badly wounded Agapito could have chased and struggled with another man, leaving the assailant to abandon his bolo.

Nature of the Statement: Confession or Admission

The trial court treated the appellant’s declaration as an extrajudicial confession. The Supreme Court disagreed with that characterization and held that the appellant’s statement was, at most, an admission. The Court explained the distinction under Sections 26 and 33, Rule 130, Rules of Court: a confession is an acknowledgment in express terms of guilt of the crime charged, whereas an admission is a statement of fact which, when considered with other evidence, tends to prove guilt but is not itself an acknowledgment of criminal intent.

Admissibility and Evidentiary Effect of the Statement

Whether characterized as a confession or an admission, the Court held that the statement was admissible against the appellant. The Court further explained that once the admission was proved, the evidentiary burden shifted to the appellant to disprove the admission or to show that she was not guilty despite it. The Court found no violation of Section 12, Article III of the Constitution because the appellant was not under investigation or in custody at the time she made the statement.

Corpus Delicti and Corroboration

The Court addressed the appellant’s contention that Eclipse’s testimony required corroboration by Liban or other witnesses. It noted that Section 3, Rule 133 requires corroboration of an extrajudicial confession by evidence of corpus delicti and emphasized that the corroboration must be with respect to the commission of the crime, not necessarily by testimony of the person who heard the statement. The Court found that corpus delicti had been overwhelmingly established by the condition of the victim and the other physical evidence in the record.

Credibility and Standard of Appellate Review

The Court reiterated the settled rule that findings on witness credibility by the trial court are accorded great weight on appeal because the trial court observed the witnesses. The Court found no ground to depart from the trial court’s credibility determinations and observed that the absence of any showing of improper motive on Eclipse’s part reinforced the trial court’s acceptance of his testimony.

Evaluation of Alleged Inconsistencies and Suppressed Evidence

The Court found the inconsistencies between the testimonies of Liban and Eclipse to be minor and not undermining credibility. It rejected the appellant’s claim of suppression of evidence concerning another police officer who may have accompanied Eclipse, noting that such testimony would have been merely corroborative and that there was no showing the witness was unavailable to the defense. The Court applied Section 3(e), Rule 131 and concluded that the presumption against the prosecution for suppression did not apply under the circumstances.

Circumstantial Evidence and Combined Inferences

The Court found, alternatively, tha

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