G.R. No. 111193 - People vs. Suarez

Case Summary (G.R. No. 111193)

Factual Background

In the early hours of December 8, 1987, intruders entered the bungalow residence of Estrellita Guzman in Barrio Capitolyo, Pasig. Estrellita was found bleeding and subsequently died of stab wounds identified at autopsy. Present in the house were Estrellita, her adopted nieces Maria Prescilla Guzman and Maria Cristina Guzman, Maria Victoria G. Suarez (Marivic), Marivic's husband Ferdinand Suarez (Jojo), their three children, and the maid Arlene Tuyor. Tuyor testified that intruders gagged and bound her, and that she saw Suarez in the house amid masked men. Items found at the scene included a half-eaten chicken, black nylon cloths, ropes, pieces of cloth and strands of ordinary wire. Investigators noted the kitchen door dead bolt was intact while the chain lock anchor had been detached and a wire inserted in the doorknob.

Investigation and Statements

The NBI conducted further investigation at the request of the family and assigned Atty. Salvador Ranin. The NBI concluded that entry could only have been effected with the aid of someone inside because the dead bolt could only be released from within. Suarez gave an initial account to the Eastern Police District consistent with being a victim of assault and abduction during the incident. Suarez later gave a sworn statement to the NBI in which he admitted supplying duplicate keys, disengaging the bolt of the kitchen door, and participating in the robbery plot under duress after threats to kill him and his family. Reyes likewise gave a sworn statement implicating Lara and describing the plan, the duplicate keys, the entry, the tying of occupants, the taking of valuables, the cooking and drinking by the malefactors, and the stabbing of Estrellita. Lara was arrested, confessed, and gave a sworn statement describing his role as introducing Suarez to Reyes and the gang but denying active participation in the house invasion and denying receipt of loot.

Indictment and Trial

An information for robbery with homicide was filed against the accused and was tried as Criminal Case No. 72249 in the Regional Trial Court of Pasig. The information alleged conspiracy and the taking of specified valuables with a value alleged at P650,000, and charged that while committing the robbery the accused, armed with bladed weapons and with intent to kill, stabbed Estrellita causing her death. Only Suarez, Reyes and Lara were apprehended and arraigned; the other accused evaded arrest. All three pleaded not guilty at trial while contesting the voluntariness and admissibility of their extrajudicial confessions.

Trial Court Findings and Sentence

The trial court admitted the extrajudicial confessions and other circumstantial evidence, found Suarez, Reyes and Lara guilty beyond reasonable doubt of robbery with homicide, and sentenced them to reclusion perpetua. The court further imposed civil indemnities of P30,000 as death indemnity and P420,000 for loss of earning capacity, and costs. Suarez and Reyes accepted the judgment while Lara appealed only his conviction and the admissibility of the extrajudicial declarations.

Issues on Appeal

Appellant Lara challenged the admissibility of the extrajudicial confessions marked as Exhibits O, P and Q, asserting that the confessions were obtained by violence, torture and intimidation and without effective assistance of counsel in violation of Section 12, Article III of the Constitution. He argued that his co-accused' confessions could not be used against him unless those confessions complied with constitutional requirements. Lara further contended that the evidence did not establish that he acted as a principal or co-conspirator in the robbery with homicide.

Standard for Admissibility of Extrajudicial Confessions

The Court reiterated that once the prosecution shows compliance with pre-interrogation advisories required by Section 12, Article III of the Constitution, a confession is presumed voluntary and the declarant bears the burden of proving that the confession was involuntary. The accused must overcome this presumption by proving violence, intimidation, threat, or promise induced the confession. The presence of counsel during custodial investigation and testimony from prosecution witnesses who witnessed the taking of the statements weigh in favor of voluntariness. Failure to complain promptly to the swearing officer or to file charges against alleged maltreaters further supports voluntariness.

Application to Reyes and Lara’s Statements

The Court examined the record and agreed with the trial court that Reyes' and Lara's extrajudicial confessions were freely and voluntarily given. The signed statements recited that the declarants were advised of constitutional rights and that counsel assisted in the custodial investigation. Prosecution witnesses present at the taking of the statements testified to the regularity of the proceedings. The accused produced no convincing independent proof of coercion. The Court found the retractions to be belated and unconvincing. Accordingly, Reyes' confession could be used as corroborative circumstantial evidence against Lara under the doctrine permitting interlocking confessions to rebut the res inter alios acta rule.

Weight of a Confession and Corpus Delicti

The Court reiterated established doctrine that an extrajudicial confession, if freely and voluntarily made, is a strong form of evidence and may convict in conjunction with proof of the corpus delicti. The Court also noted that an accused need not be shown by eyewitness testimony to have actively committed the crime if he has given a confession that satisfies the Rules of Court and is corroborated. The Rules of Court were cited as permitting the declaration of an accused acknowledging guilt to be given in evidence against him, subject to the necessity of corroborating evidence for extrajudicial confessions.

Appellant Lara’s Role and Criminal Liability

Although Lara admitted in his statement that he introd

Case Syllabus (G.R. No. 111193)

Parties and Procedural Posture

People of the Philippines prosecuted the case as plaintiff-appellee in the Regional Trial Court of Pasig, Branch 152, Criminal Case No. 72249.
Ferdinand Suarez, Loreto Reyes, and Wilfredo Lara were the three accused brought to trial while other named accused remained at large.
Wilfredo Lara, Accused-Appellant appealed the conviction imposed by the lower court.
The trial court was presided over by Judge Manuel A. Patron as stated in the record.
The decision on appeal was authored by Justice Regalado with Justices Romero, Puno, Mendoza and Torres, Jr., concurring.

Key Factual Allegations

At around 3:00 A.M. on December 8, 1987, intruders entered the household of Estrellita Guzman at Barrio Capitolyo, Pasig, and bound several occupants.
The occupants included members of the Guzman household and resident Ferdinand Suarez, who was alleged to have facilitated entry.
Estrellita Guzman sustained fatal stab wounds and later died from severe hemorrhage, as established by the post-mortem examination.
Physical items found at the scene included a half-eaten chicken, black nylon cloths, ropes, cloths, and two strands of ordinary wire which informed initial police observations.
Police noted a wire in the kitchen door knob and a detached chain anchor yet an intact dead bolt, which led to suspicion of inside assistance.
Suarez first gave an account to EPD Patrolman Pablo Roxas and later gave a sworn statement to the NBI admitting he aided the intruders by giving duplicate keys and releasing the kitchen bolt.
Reyes gave a written statement implicating himself, Lara, and others, alleging a plot to rob and to kill Estrellita for alleged financial gain and naming participants who stabbed the victim.
Lara later gave a sworn statement admitting he introduced Reyes' group to Suarez but denied direct participation in the actual killing and denied receiving a share of the loot.

Evidence and Confessions

The prosecution relied substantially on extrajudicial confessions identified in the record as Exhibits O, P and Q.
The NBI recovered duplicate keys used by the intruders, which were introduced as Exhibit R-5, and identified them through Reyes' admissions.
Photographs of reenactments were presented as Exhibits BB and CC, but the trial court considered their probative value with reference to counsel assistance at the reenactment.
Several prosecution witnesses testified to the regularity and voluntariness of the custodial investigations and the observance of constitutional advisories.

Procedural History

An information for robbery with homicide was filed in Pasig based on NBI submissions charging the named accused with conspiracy and robbery with homicide.
The accused pleaded not guilty at trial and subsequently attempted to exclude their NBI statements on grounds of coercion and lack of counsel.
The trial court found Suarez, Reyes, and Lara guilty beyond reasonable doubt and imposed reclusion perpetua with civil indemnities as reflected in the lower court judgment.
Suarez and Reyes accepted the trial court verdict while Lara appealed contesting the admissibility of the extrajudicial confessions and his degree of criminal liability.

Issues Presented

Whether the extrajudicial confessions of the accused were admissible and voluntary in compliance with Section 12, Article III of the Constitution.
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