G.R. No. 262579 - People vs. Rossano Samson Tiongco

Case Summary (G.R. No. 262579)

Factual Background

On the evening of October 8, 2014, Jeremias B. Dela Torre left his house to fetch his wife while his eleven-year-old daughter, Abegail Tobias y Dela Torre, attended a dance practice. Upon returning, Jeremias and his wife found bloodstains in the house and later discovered Abegail lifeless at the side of the road across their house, drenched in blood, with her blouse lifted to her breast and her underwear pulled down to her right ankle. Neighbors told investigators that a drinking spree had occurred earlier that day and that among those present only the accused-appellant had left the area. A plastic bead from an earring was observed at the doorstep of the accused-appellant’s house and was identified by Jeremias as belonging to Abegail. The accused-appellant was later found sleeping at his father’s house in Navotas, and while being taken to the police station he admitted that he killed Abegail and subsequently executed an extrajudicial confession, with Atty. Mario M. Villegas assisting him. The Medical-Legal Report indicated that Abegail sustained thirty-two injuries, three of which were fatal and located on the head, including a fracture on the frontal bone. The crowbar alleged to have been used was recovered from the accused-appellant’s house.

Trial Court Proceedings

The accused-appellant pleaded not guilty and underwent trial on the merits before Branch 18, RTC, Malolos City. The RTC found guilt proven beyond reasonable doubt and convicted him of Murder under Article 248, as qualified by treachery and abuse of superior strength, and sentenced him to suffer reclusion perpetua without eligibility for parole. The RTC also ordered payment of civil indemnity (PHP 100,000), actual damages (PHP 50,570), moral damages (PHP 100,000), and exemplary damages (PHP 100,000), with six percent interest per annum from finality of the decision until full payment.

The Parties’ Contentions

The prosecution relied on eyewitness and investigative testimony, physical evidence recovered at the accused-appellant’s premises, the medical findings, the accused-appellant’s extrajudicial confession, and the pattern of the accused-appellant’s conduct after the incident to prove guilt. The defense denied the charge, asserted alibi and lack of knowledge of the events, and contended that the extrajudicial confession was not valid because the accused-appellant could not read the document he signed and was improperly induced to sign it.

Ruling of the Court of Appeals

The Court of Appeals denied the accused-appellant’s appeal in CA-G.R. CR HC No. 14958 and affirmed the RTC Decision in toto on April 19, 2022. The CA upheld the RTC’s findings on the elements of murder, on the qualifying circumstance of treachery and abuse of superior strength, and on the admissibility and probative value of the extrajudicial confession and the circumstantial evidence that pointed to the accused-appellant as the perpetrator.

Issues Presented to the Supreme Court

The appeal raised two principal issues: whether the CA erred in affirming the trial court’s admission of the accused-appellant’s extrajudicial confession, and whether the CA erred in affirming conviction based principally on circumstantial evidence.

Ruling of the Supreme Court

The Supreme Court dismissed the appeal and affirmed the rulings of the RTC and the CA with modification. The Court found that the prosecution established, beyond reasonable doubt, the elements of Murder under Article 248 and that the killing was qualified by treachery, which absorbed the circumstance of abuse of superior strength. The Court held the extrajudicial confession admissible and reliable and sustained the conviction based on the totality of the circumstantial evidence. The Court modified the damages to conform with People v. Jugueta, reducing civil indemnity, moral damages, and exemplary damages to PHP 75,000 each, while affirming actual damages of PHP 50,570 and the imposition of six percent interest per annum from finality until full payment. The Court sentenced the accused-appellant to reclusion perpetua and emphasized that the phrase “without eligibility for parole” need not be added under A.M. No. 15-08-02-SC.

Legal Basis and Reasoning on the Elements of Murder

The Court restated the elements of Murder under Article 248: (a) that a person was killed; (b) that the accused killed him or her; (c) that the killing was attended by any qualifying circumstance enumerated in Article 248; and (d) that the killing was not parricide or infanticide. The Court found each element present. The victim was an eleven-year-old child whose minority alone supported the finding of treachery because a child’s tender age and inability to resist render the attack free from any risk to the assailant. The Court concluded that treachery absorbed any separate treatment of abuse of superior strength and therefore classified the offense as murder qualified by treachery only.

Circumstantial Evidence Findings

The Court applied the established test for conviction by circumstantial evidence, reiterating the requisites that there be more than one circumstance, that the facts from which the inferences are drawn be proven, and that the combined circumstances produce a conviction beyond reasonable doubt. The Court found that the circumstantial proof formed an unbroken chain connecting the accused-appellant to the crime. Relevant circumstances included the accused-appellant’s voluntary extrajudicial confession describing the manner of killing; corroboration of that description by the Medical-Legal Report; recovery of a plastic bead from the accused-appellant’s doorstep identified as belonging to the victim; recovery of the crowbar at the accused-appellant’s house; evidence that the accused-appellant had been intoxicated and participated in the drinking spree; and the accused-appellant’s flight to his father’s house in Navotas shortly after the incident. The Court held that these circumstances, when woven together, pointed fairly and reasonably to the accused-appellant to the exclusion of others and outweighed his bare denial and unsupported alibi.

Admissibility of the Extrajudicial Confession

The Court considered the legal requisites for admissibility of an extrajudicial confession: voluntariness, assistance of a competent and independent counsel, expressness, and that the confession be in writing and signed. The Court also applied the constitutional safeguards and the specific requirements of Section 2(d) of Republic Act No. 7438. The Court found that the Office of the Mayor requested the Public Attorney’s Office to summon Atty. Villegas; that Atty. Villegas met exclusively with the accused-appellant, informed him of his rights and the consequences of confession, and that the accused-appellant repeatedly stated that he was conscience-stricken; and that the confession was made in writing and signed in counsel’s presence. The Court therefore deemed the confession voluntary, made with competent independent counsel, and admissible under RA 7438.

Evaluation of the Defense and Credibility Findings

The Court accorded gr

Case Syllabus (G.R. No. 262579)

Parties and Posture

PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, prosecuted the crime of Murder under Article 248 of the Revised Penal Code against the accused.
ROSSANO SAMSON Y TIONGCO, ACCUSED-APPELLANT, pleaded not guilty and was tried before Branch 18, Regional Trial Court, Malolos City, Bulacan.
The RTC found the accused guilty of Murder and sentenced him to reclusion perpetua and monetary awards, and the Court of Appeals affirmed the conviction.
The appeal to the Supreme Court (Third Division, G.R. No. 262579) assailed the CA decision affirming the RTC judgment, principally contesting the admissibility of the extrajudicial confession and the sufficiency of circumstantial evidence.

Key Facts

The victim, Abegail Tobias y Dela Torre, an eleven-year-old female minor, was found lifeless and bleeding near her family home with her blouse lifted and underwear displaced.
The father, Jeremias B. Dela Torre, observed blood in the house and later identified a plastic bead found at the accused's doorstep as part of the victim's earring pendant.
Neighbors had a drinking spree on the day of the incident during which only the accused left the scene, and the accused was observed by Jeremias to be intoxicated when they crossed paths.
The accused fled to his father's house in Navotas where police found him sleeping the next day, and he admitted during transport and at the police station that he killed the victim with a crowbar.
A medico-legal report by Dr. Editha B. Martinez showed thirty-two injuries on the victim, including three fatal head injuries and a fracture of the frontal bone.
A crowbar alleged to be the instrument of the killing and the plastic bead from the victim's earring were recovered from the accused's household.

Procedural History

The accused was arraigned and pleaded not guilty before the RTC and underwent trial on the merits.
On July 20, 2020, the RTC convicted the accused of Murder and imposed reclusion perpetua, civil indemnity, actual, moral, and exemplary damages, and legal interest.
The accused appealed to the Court of Appeals, which, in a decision dated April 19, 2022, denied the appeal and affirmed the RTC judgment in toto.
The accused elevated the case to the Supreme Court, which heard the appeal on assigned errors without supplemental briefs after manifestations by the parties.

Issues Presented

Whether the Court of Appeals erred in affirming the trial court's admission of the accused's extrajudicial confession.
Whether the Court of Appeals erred in affirming the trial court's conviction of the accused based on circumstantial evidence.

Ruling and Disposition

The Supreme Court dismissed the appeal and affirmed with modification the decision of the Court of Appeals and the RTC conviction of the accused for Murder under Article 248 of the Revised Penal Code.
The accused was sentenced to suffer the penalty of reclusion perpetua.