Case Summary (G.R. No. 117202)
Applicable Law
The framework for this decision is based on the 1987 Philippine Constitution, which emphasizes the rights of the accused during custodial investigations, particularly the right to counsel and to be informed of one’s rights.
Factual Background
On July 10, 1990, an Information was filed with the Regional Trial Court in Olongapo City against Deorito Porio, charging him with committing rape and subsequently murdering Riza Cleodoro Flores. The prosecution presented several witnesses, including medical professionals and police officers, who testified to the events surrounding the crime. The forensic examination revealed that the cause of death was strangulation and indicated evidence of sexual intercourse.
Prosecution's Evidence
Witness testimonies indicated that the victim was found dead near a creek. Dr. Richard Patilano, a medico-legal officer, confirmed that the autopsy indicated strangulation as the cause of death and noted injuries consistent with sexual assault. Furthermore, community leader Francisco Montes testified that Deorito had attempted to rape Riza on prior occasions and later confessed to both the rape and murder albeit in a non-verbalized manner until a formal confession was taken.
Confession Details
On January 27, 1990, while in police custody, Deorito Porio made a verbal confession, which was later documented in his Sinumpaang Salaysay. During this confession, Porio detailed the events leading to the crime, stating that he attacked Riza after being under the influence of alcohol and that he strangled her after the sexual assault.
Defense and Trial
During the trial, the defense focused on challenging the admissibility of the confession, claiming it was obtained without the benefit of competent legal counsel and that it was coerced. Deorito Porio took the stand, denying the charges and asserting that he did not voluntarily confess, stating he was unsure of the lawyer present during his confession process.
Decision of the Trial Court
On July 20, 1994, the trial court found Deorito Porio guilty beyond a reasonable doubt of rape with homicide. He was sentenced to reclusion perpetua, and the court awarded civil, moral, and exemplary damages.
Appellate Issue
Deorito Porio appealed, arguing multiple errors, including improper admittance of his confession, insufficient evidence, and the weight given to prosecution witnesses over defense evidence.
Examination of Confession Validity
The appellate court held that the extra-judicial confession was admissible. It adhered to constitutional safeguards articulated in Article III, Section 12 (1) of the 1987 Constitution, emphasizing that the confession was voluntary and made in the presence of competent counsel. The court established that the burden was on the accused to prove coercion, which he failed to do. The defense's claims did not sufficiently demonstrate duress or coercion, and the confession was made with a
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Case Overview
- Court: Supreme Court of the Philippines, Third Division
- Date of Decision: February 13, 2002
- Citation: 427 Phil. 82
- G.R. No.: 117202
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Deorito Porio y Rapsing
- Nature of the Case: Complex crime of rape with homicide.
Facts of the Case
- On July 10, 1990, Deorito Porio was charged with the crime of rape with homicide of an 11-year-old girl, Riza Cleodoro Flores.
- The allegations stated that on June 25, 1990, in Olongapo City, Porio, with lewd design, had carnal knowledge of Riza and subsequently strangled her to death.
- Riza's lifeless body was discovered near a creek shortly after midnight on June 25, 1990, showing signs of strangulation and evidence of sexual assault.
- An autopsy conducted by Dr. Richard Patilano confirmed the cause of death as neurogenic shock and asphyxia by strangulation, with physical evidence of sexual intercourse.
Procedural History
- The accused pleaded "not guilty."
- The prosecution presented several witnesses, including police officers and medical experts.
- The defense consisted solely of the testimony of the accused, who denied the charges.
- The trial court found Porio guilty beyond reasonable doubt and sentenced him to reclusion perpetua, along with damages to the victim's family.
Key Testimonies
- Prosecution witnesses testified about the discover