Title
People vs. Omilig y Mancia
Case
G.R. No. 206296
Decision Date
Aug 12, 2015
Accused-appellant convicted for 1993 murder in Iligan City; extrajudicial confessions deemed admissible, no rights violation, corpus delicti proven. Damages awarded to victim’s heirs.

Case Summary (G.R. No. 206296)

Key Dates and Procedural Posture

Incident: August 21, 1993. Initial Information filed: September 7, 1993; Amended Informations: November 16, 1993 and subsequently to add Oscar Ondo. Extrajudicial admissions/confessions obtained: November 12–13, 1993. Trial before RTC Branch 5, Iligan City, resulted in conviction of Peaaflor and acquittal of the other accused. The Court of Appeals affirmed. The Supreme Court reviewed and rendered the final decision affirming conviction with modifications to the damages awarded.

Applicable Law

Criminal offense charged: Murder under Article 248 of the Revised Penal Code. Constitutional and statutory provisions controlling admissibility of confessions and rights during custodial interrogation: Article III, Section 12(1) of the 1987 Constitution (right to remain silent and to have competent and independent counsel, preferably of one’s own choice); Section 2 of Republic Act No. 7438 (rights of persons arrested, detained, or under custodial investigation). Governing principles on admissibility of extrajudicial confessions and presumption of regularity are applied as developed in the cited jurisprudence.

Second Amended Information (Charge Summary)

The accused were charged with conspiring and mutually aiding one another to attack, assault, shoot and stab Eduardo Betonio on or about August 21, 1993 in Iligan City, armed with a firearm and a hunting knife, with intent to kill, evident premeditation and by means of treachery, resulting in Betonio’s death from cardiorespiratory arrest and hypovolemic shock due to penetrating stab wound and gunshot wounds.

Facts Established at Trial

COA auditor Danilo Estur discovered unaccounted rice stocks under the account of Matas, which led to Betonio’s suspension. On the evening of August 21, 1993, immediately after disembarking from his vehicle at his rented apartment, Betonio was stabbed and shot. Vicenta Betonio heard him shout “If you want to kill me, don’t include my wife,” then heard gunshots; she later found him slumped with a knife embedded in his chest and, before he died, heard him whisper the names “Delfin” and “Matas.” Medical examination by Dr. Villarin established cause of death consistent with stab and gunshot wounds. A characteristic knife was removed from the cadaver and later traced in evidence to accused-appellant Peaaflor.

Prosecution Evidence

The prosecution presented ten witnesses, including the COA auditor who investigated the missing rice; the homicide investigator who identified and brought Peaaflor for inquiry; lay witnesses who identified the knife and recounted the scene; the forensic pathologist who performed the post-mortem; the victim’s wife and driver who described the incident and immediate aftermath; and prosecutors and court stenographer who testified to the conduct of the preliminary investigation and the taking of Peaaflor’s extrajudicial confessions. Documentary and physical evidence included the Death Certificate, the post-mortem report and the knife allegedly extracted from the cadaver.

Defense Evidence and Contentions

The defense called eight witnesses, including co-accused Omilig who asserted an alibi (attendance at a benefit dance) and claimed coercion in signing a sworn statement; witnesses corroborating Omilig’s alibi and denying his ownership of the knife; witnesses regarding procedural matters and an earlier incident involving a burned vehicle; and counsel who testified that the extrajudicial confessions were obtained in violation of Peaaflor’s right to choose competent counsel of his own. The defense specifically argued that the lawyers assisting Peaaflor during the confessions (Atty. Cristobal and Atty. Cavales) were not counsel of his own choice and that their assistance was perfunctory or ceremonial, rendering the confessions inadmissible.

Ruling of the Regional Trial Court

The RTC acquitted co-accused Matas, Omilig and Ondo for failure of proof, but convicted Ramil Peaaflor of murder based on his extrajudicial confessions. The RTC admitted the confessions as voluntarily given, taken at the Prosecutor’s Office (not at a police station), and in the presence of relatives and counsel. The RTC sentenced Peaaflor to reclusion perpetua and ordered indemnities and damages in specified amounts.

Ruling of the Court of Appeals

The Court of Appeals affirmed conviction. It held that Peaaflor’s extrajudicial confessions were admissible because they were given during preliminary investigation before prosecutors and not during custodial interrogation by police officers. The CA adopted the established distinction that custodial investigation involves interrogation initiated by law enforcement after a person has been taken into custody or deprived of freedom in a significant way. The CA also held that even if custodial investigation were assumed, the record supported the competency and independence of the assisting counsel and that the confessions were voluntarily made.

Corpus Delicti Analysis by the Supreme Court

The Supreme Court reiterated the legal standard that corpus delicti requires proof (a) that a certain result (death) has occurred and (b) that some person is criminally responsible. It found the corpus delicti established through documentary and physical evidence (death certificate and post-mortem), the recovery and identification of the knife removed from the victim’s body, and corroborating testimonial evidence (victim’s wife and driver). Circumstantial and direct evidence together supported the fact of the murder and the involvement of the accused-appellant.

Extrajudicial Confession: Custodial vs. Preliminary Investigation

Applying the Court’s prior decisions (notably Ladiana), the Supreme Court affirmed that preliminary investigation before a public prosecutor is not the same as custodial investigation by police. The distinction matters because the constitutional and statutory protections regarding assistance of counsel and the right to remain silent are tailored to custodial interrogation, which carries a higher risk of coercion. The record showed the confessions were obtained at the prosecutors’ offices and in circumstances consistent with preliminary investigation proceedings.

Requirements for Admissibility of Confession and Counsel Assistance

The Court reiterated the requirements for an admissible confession: voluntariness, assistance of a competent and indepe

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