Case Summary (G.R. No. 216010)
Key Dates
October 8, 2014 – Commission of the crime in Norzagaray, Bulacan
July 20, 2020 – RTC Decision convicting appellant of Murder
April 19, 2022 – CA Decision affirming RTC ruling
February 28, 2024 – Supreme Court Decision
Applicable Law
1987 Philippine Constitution; Article 248, Revised Penal Code (Murder); Republic Act No. 7438 (Rights of Persons Under Custodial Investigation); A.M. No. 15-08-02-SC (Parole Phrase Guidelines); pertinent Supreme Court jurisprudence on extrajudicial confession and circumstantial evidence
Antecedents
An Information charged Rossano Samson y Tiongco with murder of his neighbor’s daughter, Abegail Tobias y Dela Torre, with treachery and abuse of superior strength, for attacking her with a crowbar on October 8, 2014, causing her instantaneous death.
Prosecution’s Version
Witness Jeremias B. Dela Torre encountered the accused intoxicated earlier that evening. Blood traces led to discovery of the victim’s body across her home. Police invited participants of a local drinking spree; only the accused fled. At his Bulacan residence they recovered a plastic earring pendant identified by the victim’s father. The accused was found hiding in Navotas, arrested, and during transportation and at the station voluntarily confessed—with counsel present—to killing Abegail using a crowbar hidden in Bulacan.
Defense’s Version
The accused denied involvement, claiming he learned of the death only by neighborhood rumors and that he went to his father’s house in Navotas for provisions. He alleged that counsel asked him to sign a document he could not read, purportedly to help his case.
RTC Ruling
The RTC found the extrajudicial confession voluntary and properly made with independent counsel. It held that all elements of murder under Article 248 were proven, including treachery and abuse of superior strength. Rossano Samson y Tiongco was convicted of Murder and sentenced to reclusion perpetua without eligibility for parole, and ordered to pay civil indemnity (₱100,000), actual damages (₱50,570), moral damages (₱100,000), and exemplary damages (₱100,000), plus 6% interest.
CA Ruling
The Court of Appeals denied the appeal and affirmed the RTC decision in toto.
Issues on Appeal
- Whether the CA erred in admitting the extrajudicial confession.
- Whether the CA erred in upholding conviction based on circumstantial evidence.
Supreme Court Ruling on Guilt
Affirmed. Factual findings of the RTC, as affirmed by the CA, are accorded respect absent any gross misapprehension of facts. The totality of evidence—voluntary confession, recovery of victim’s earring pendant and the murder weapon at the accused’s residence, flight, and intoxication—forms an unbroken chain pointing exclusively to the accused beyond reasonable doubt. Alibi and denial were unsubstantiated and inherently weak.
Qualifying Circumstance: Treachery
The Court found treachery present in the killing of an 11-year-old minor, noting that the child’s inability to resist renders any assault treacherous. Abuse of superior strength, though proven, is absorbed by treachery and should not be treated as a separate aggravating circumstance.
Circumstantial Evidence Standard
Under People v. Matignas, conviction on circumstantial evidence requires multiple proven facts, and their combination must exclude all other hypotheses but the guilt of the accused. This standard was satisfied by the collected circumstances.
Extrajudicial Confession Admissibility
Compliance with constitutional safeguards and with RA 7438 was esta
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Procedural History
- Criminal Information filed in RTC, Branch 18, Malolos City, Bulacan, docketed as Criminal Case No. 4160-M-2014, charging Murder under Article 248, RPC.
- Accused-appellant pleaded “Not Guilty.”
- RTC, Branch 18, rendered Decision on July 20, 2020, convicting accused-appellant of Murder with treachery and abuse of superior strength; sentenced to reclusion perpetua without eligibility for parole and ordered to pay civil indemnity, actual, moral, and exemplary damages.
- Accused-appellant appealed to the Court of Appeals (CA) in CA-G.R. CR HC No. 14958.
- CA, in its Decision dated April 19, 2022, affirmed the RTC Decision in toto.
- Accused-appellant elevated the case to the Supreme Court via Petition for Review on Certiorari under Rule 45, raising errors on admission of extrajudicial confession and reliance on circumstantial evidence.
Facts of the Case
- On October 8, 2014, around 6:30 p.m., victim Abegail Tobias y Dela Torre (11-year-old minor) attended dance practice.
- Her father, Jeremias B. Dela Torre, saw accused-appellant, a former carpentry co-worker, en route to fetch his wife. Accused-appellant nodded when told of next day’s work.
- Upon return home, Jeremias and wife found bloodstains inside house; Abegail was later discovered lifeless across the road, blouse raised, underwear pulled down.
- Barangay Captain summoned Norzagaray police; SPO3 Dennis R. Diaz rounded up men from a drinking spree. Only accused-appellant left the scene, prompting investigation at his house.
- Police recovered a plastic bead (earring pendant) at accused-appellant’s doorstep, identified by Jeremias as belonging to Abegail.
- Accused-appellant was found sleeping at his father’s house in Navotas; during transport to the station, he confessed to killing Abegail with a crowbar, which he later led police to retrieve in Bulacan.
Versions of the Parties
- Prosecution: Established murder through eyewitness identification of pendant, forensic findings (32 injuries, three fatal to the head, including skull fracture), accused-appellant’s voluntary extrajudicial confession aided by counsel Atty. Mario M. Villegas, and flight to Navotas.
- Defense: Denial of participation; claimed he learned of t