Case Summary (G.R. No. 117166-67)
Key Facts
Erliste Arcilla Francisco was last seen on February 28, 1992, in the company of Domingo Francisco, who worked as a janitor at UERM Hospital. On March 1, 1992, a charred female body was discovered in Barangay Cupang, Antipolo, identifiable only by personal effects. Initially arrested based on information from Erliste's mother and corroborated by witness statements, Domingo Francisco subsequently implicated his co-accused, leading to the filing of two separate informations: one charging Domingo with Parricide and the other charging the three co-accused with Murder.
Proceedings and Evidence
The prosecution’s case relied heavily on the alleged confessions made by the accused during their arrest and custodial investigation—a critical point contested on appeal. Witnesses included law enforcement officials who testified to admissions made by the accused and those who established the motive stemming from domestic issues, such as infidelity and domestic violence.
Custodial Investigation and Confessions
Crucially, the law enforcement officers involved admitted that the confessions were made without the presence of an attorney, constituting a potential violation of the accused's rights as enshrined in Article III, Section 12 of the 1987 Philippine Constitution, which prohibits admissible confessions obtained during custodial interrogation without counsel. Notably, these alleged confessions were neither written down nor corroborated with independent documentation.
Evidence of Corpus Delicti
The court found the prosecution failed to adequately establish proof of the corpus delicti, given that the body was barely recognizable and identification relied on hearsay witnesses. The court noted that key witnesses could not affirmatively identify the victim, thereby rendering the evidence against the accused unreliable.
Motive and Guilt
While motive was discussed extensively—domestic strife and the alleged involvement of a paramour—the court emphasized that motive alone does not constitute proof of guilt beyond a reasonable doubt. The defense successfully argued that the prosecution's reliance on vague and contradictory testimonies u
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Case Overview
- This case is an appeal from the decision of the Regional Trial Court, Branch 73, of Antipolo Rizal.
- The accused-appellant Domingo Francisco was found guilty of Parricide, while co-accused-appellants Randy Mantes, Jerome Garcia, and Jovy Velasco were found guilty of Murder for the death of Erliste Arcilla Francisco.
- All accused-appellants were sentenced to reclusion perpetua and ordered to indemnify the victim's heirs in the amount of P50,000.00, plus costs of suit.
Facts of the Case
- Domingo Francisco, the husband of Erliste Arcilla Francisco, was last seen with her at UERM Hospital on February 28, 1992.
- Erliste was reported missing, and her charred body was discovered the following day in Barangay Cupang, Antipolo, Rizal.
- Police investigations were initiated based on information from Erliste's mother, Dominga Arcilla, and a witness, Alice Francisco, implicating Domingo and his co-accused.
- Charges were filed against Domingo for Parricide and against the others for Murder on March 12, 1992.
Charges and Allegations
- The charge against Domingo Francisco alleged that he conspired with the others to kill Erliste, employing premeditation and brutal methods including assault, strangulation, and burning.
- The charges against Mantes, Garcia, and Velasco similarly alleged conspiracy with the intent to kill, taking advantage of superior strength.
Trial Proceedings
- The trial included testimonies from police officers who arrested the accused, with some claiming admissions of guilt made by the accuse