People v.

Español
Facts:
- RTC of Dagupan City convicted the appellant of the crime of parricide and sentencing him to reclusion perpetua.
Appellant was charged with killing his wife, Gloria
- Appellant pleaded no guilty to the charge. During the pre-trial, the following facts were stipulated:
- The victim was the legal wife of the appellant
- Gloria and the appellant were living together as husband and wife prior to the incident
- Before the victim was shot, appellant borrowed a tricycle from Federico Ferrer and drove the said tricycle with his
wife from their house to the house of the victim’s sister.
- The appellant and the victim lived in their own house with 4 children
- Background Facts:
- Domingo was waiting for his companions at Pantal Road in Dagupan. They were on their way to Manila. They heard
2 gunshots. Thereafter, a yellow tricycle sped past him along the road driven by a man wearing a dark-colored long
sleeved shirt.
- Domingo and his companions thereafter saw a lifeless body along the road. They discovered it was the body of
Gloria. They reported this to the police.
- Gunshots were also heard by Harold, a boatman working along the river, while he was waiting for passengers at the
dock about 100m from the crime scene
- The shots were followed by the sound of a motorcycle’s revving engine. Saw the same yellow tricycle, which bore
the name “Rina” in front of its cab. He also saw the driver wearing a dark jacket and blue pants. The boatman also
saw a dead body and was later found out to be Gloria.
- Moments later, the appellant arrived at the scene of the crime. He immediately assumed that Gloria was killed in a
robbery.
- Harold noticed that the appellant seemed to be wearing the same clothes as the tricycle driver he saw speeding along
the road after the gunshots
- The brother of the deceased was fetched by appellant using the same tricycle bearing the name “Rina” printed at the
front. On the way to the crime scene, the brother noted that the seats and the floor were wet, when asked about it,
appellant did not answer
- At the mourge, appellant refused to look at the body and preferred to stay outside
- The sister of the deceased, disturbed by the acts of appellant, asked the police to interrogate the appellant. The police
officer asked the sister if they could talk in private. During their talk, the appellant begged the sister for forgiveness and
asked that he be spared from imprisonment.
- During the victim’s wake, appellant hardly looked at the remains. He stayed inside the house. He repeatedly asked for
forgiveness from the sister. The nephew of the deceased asked why the appellant killed Gloria, appellant just kept
silent.
- The other sister of the accused also disclosed that the appellant had an illicit relationship with a certain Eva, and the
latter was confronted by Gloria— appellant took the side of Eva
- RTC ruled against appellant. Appellant basically denied that he asked forgiveness for the killing. Denied also that he
had a relationship with Eva. The children of appellant also corroborated the testimony of appellant and maintained that
he was at their house resting at the time of the commission of the crime
- CA affirmed the RTC

Issue: Whether appellant is guilty of the crime of parricide— Yes

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Held:
- The following circumstances proved beyond reasonable doubt that appellant was guilty beyond reasonable doubt:
- He admitted that he was the one who brought his wife to the scene of the crime minutes before the latter’s body
was discovered
- The tricycle used in transporting his wife was the same tricycle seen by the witnesses mentioned above
- The assertion of robbery is untenable since it was found that all the wife’s possessions remained intact
- Appellant did not respond to his brother in law’s query as to why the tricycle sidecar was wet
- Appellant repeatedly asked for forgiveness from the sister
- Appellant had a paramour before the incident
- Direct evidence of the actual killing is not indispensible for convicting an accused when circumstantial
evidence can adequately establish his or her guilt. Requisites:
- More than 1 circumstance
- Such circumstances were proven as facts
- Combination of all circumstances is such as to produce a conviction beyond reasonable doubt
- In the present case, none of the prosecution witnesses saw the actual killing. HOWEVER, their separate and detailed
accounts of the surrounding circumstances reveal only 1 conclusion: that it was appellant who killed his wife
- The trial court’s evaluation of the testimonies of the witnesses is accorded great respect in the absence
of proof that it was arrived at arbitrarily or that the trial court overlooked material facts
- Appellant’s bare denial that he did not kill his wife is a negative and self-serving assertion— merits no weight
- Cannot be given greater weight than the testimony of a credible witness who testified on affirmative matters. No ill
motive was shown to fabricate charges
- Alibi is inherently weak. The argument that he was at his house at the time of the incident is untenable since he
failed to prove the physical impossibility of him being at the crime scene at that time
- RELEVANT DISCUSSION:
- Another piece of evidence was his silence when his wife’s nephew asked why he killed his wife
- Sec. 32 Rule 130— Admission by Silence— an act or declaration made in the presence and within the
hearing observation of a party who does or says nothing when the act or declaration is such as
naturally to call for action or comment if not true, and when proper and possible for him to do so,
may be given in evidence against him
- Appellant’s act of asking for forgiveness can also be equivalent to an offer to compromise which can be
received as an implied admission of guilt
- Sec. 27, Rule 130—-In criminal cases, except those involving quasi offenses, or those allowed by law
to be compromised, an offer for compromise by the accused may be received in evidence as an
implied admission of guilt
- In conclusion, the appellant’s guilt was sufficiently proved by circumstantial evidence

People v. Pilones
Facts:
- April 9— during a wake in a house in Sta. Ana, Manila, Ilagan and Renolla were present. Shortly after midnight, the
house where the vigil was held was stoned. Ilagan and the others came out of the house and went to the street to find
out who threw the stones

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- As Ilagan stood on the lighted street, he was shot in the knee. Because of the lighted street, Ilagan was able to identify
his assailant’s face.
- Renolla also went out of the house to assist Ilagan. He was shot in the chest and died.
- The assailant and his companions were armed with arrows and carried stones. They ran away after the incident.
- Ilagan, while in the hospital, was informed by one of friends that his assailant was Pilones (the assailant)
- 50 days after the shooting, the police arrested the assailant for vagrancy. Renolla’s mother identified Pilones as the
assailant in the shooting incident.
- Thereafter, Ilagan indeed confirmed and identified Pilones as the assailant in the shooting incident in the precinct.
- Pilones refused to given any statement or comment at that investigation
- The assailant offered the defense of alibi. He argued that when the shooting occurred, he was in the house of his aunt at
Olongapo City. However, his aunt and brother in law in the said house did not testify as to this fact. A neighbor was also
presented to corroborate his alibi, but such tesitmony was weakened by a serious contradiction— at first she said before
Christmas, the assailant left for Olongapo, while the brother in law said that assailant went to the said city after
Christmas
- The personal circumstances of Pilones were also taken into consideration— he had a common law wife; he had tattoos
place by a certain Ben Lumot; assailant claimed that he was framed by the police who disliked him

Issue: Whether Pilone was sufficiently identified by the prosecution’s sole eyewitness as the assailant of Renolla— Yes

Held:
- It was argued that during his stay in the hospital, metallic fragments were extracted from Ilagan’s knees. On the other
hand, the autopsy on the cadaver of Renolia there was recovered a .22 bullet— appellant argues that Ilagan and Renolia
were shot by different persons or with different weapons
- untenable. Merely conveys the impression that Ilagan and Renolia were shot in succession and that Pilones used
different weapons. Assailant had time to change weapons. He also had companions who could have assisted him in
the execution of the crime
- The fact remains that Ilagan positively identified Pilones as the person who shot him. Even if Renolia was shot by a
companion of the assailant, with a firearm different from the .22 caliber rifle used against Ilagan, Pilones would still be
liable because he conspired with the person who shot Renolia— they were together at the scene of the crime; they left
the place together; they had community of design
- Pilones was also identified not only identified by Ilagan during the confrontation, but also during the events in the
police precinct
- RELEVANT:
- Pilones just kept silent and did not deny the accusation of Ilagan and Renolia’s mother
- “he who remains silent when he ought to speak cannot be heard to speak when he should be silent”
- Silence is assent as well as consent, and may, where a direct and specific accusation of crime is made,
be regarded, under some circumstances as a quasi-confession
- An innocent persons will at once naturally repel an accusation of a crime as a matter of self-defense,
and as a precaution against prejudicing himself— a persons’s silence, when it is persistent, will
justify an inference that he is not innocent

People v Baharan
Facts:

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- On 14 February 2005, an RRCG bus was plying its usual southbound route, via Epifanio de los Santos Avenue (EDSA).
According to Elmer Andales, bus conductor, two men insisted on getting on the bus, so the conductor obliged and let
them in.
- During the bus ride, the said conductor noticed that the 2 men were acting suspiciously; the men were seated
separately; when each of them were asked if they were going to pay for 2 persons, both of them answered yes, the
man seated at the bank was seemed to be holding something and was covering it from the view of the conductor.
- As soon as the bus reached the stoplight at the corner of Ayala Avenue the two immediately got off the bus and ran.
- The 2 men insisted that they be dropped of in an intersection. The bus driver initially hesitated to allow them, since
this was in violation of a traffic ordinance. But eventually the driver conceded to the request.
- Moments after, they felt an explosion and then saw fire quickly engulfing the bus.
- The prosecution presented documents furnished by the Department of Justice, confirming that shortly before the
explosion, the spokesperson of the Abu Sayyaf Group - Abu Solaiman - announced over radio station DZBB that the
group had a Valentine's Day "gift" for former President Gloria Macapagal-Arroyo.
- Trinidad (one of the accused) gave ABS-CBN News Network an exclusive interview some time after the incident,
confessing his participation in the Valentine's Day bombing incident.
- The bus conductor identified Baharan and Trinidad, and confirmed that they were the two men who had entered the
RRCG bus on the evening of 14 February.
- Members of the Abu Sayyaf Group were then charged with multiple murder and multiple frustrated murder.
- Only Baharan, Trinidad, Asali, and Rohmat were arrested, while the other accused remain at-large. Baharan and Trinidad
pled guilty to the charge of multiple frustrated murder.
- Note: they intially plead guilty to the charge of murder, but denied the frustrated murder case; however, the
pleaded guilty to the said charge upon consultation with their counsel about the possible ramifications of them
pleading guilty to the murder charge

Issues:
(1) Whether the trial court gravely erred in accepting plea of guilt despite insufficiency of searching inquiry into the
voluntariness and full comprehension of the consequences of the said plea— No
- This court have reiterated in a long line of cases that the conduct of a searching inquiry remains the duty of judges, as
they are mandated by the rules to satisfy themselves that the accused had not been under coercion or duress; mistaken
impressions; or a misunderstanding of the significance, effects, and consequences of their guilty plea. This requirement
is stringent and mandatory.
- The Court observes that accused Baharan and Trinidad previously pled guilty to another charge - multiple murder -
based on the same act relied upon in the multiple frustrated murder charge.
- The Court further notes that prior to the change of plea to one of guilt, accused Baharan and Trinidad made two other
confessions of guilt - one through an extrajudicial confession (exclusive television interviews, as stipulated by both
accused during pretrial), and the other via judicial admission (pretrial stipulation).
- Considering the foregoing circumstances, we deem it unnecessary to rule on the sufficiency of the "searching inquiry"
in this instance. Remanding the case for re-arraignment is not warranted, as the accused's plea of guilt was not the sole
basis of the condemnatory judgment under consideration

(2) Whether the trial court gravely erred in finding that the guilt of accused-appellants for the crimes charged had been
proven beyond reasonable doubt.— No

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- Insofar as appellants Baharan and Trinidad are concerned, the evidence for the prosecution, in addition to that which
can be drawn from the stipulation of facts, primarily consisted of the testimonies of the bus conductor, who positively
identified accused Baharan and of the accused turned-state-witness.
- The guilt of the accused Baharan and Trinidad was sufficiently established by these corroborating testimonies, coupled
with their respective judicial admissions (pretrial stipulations) and extrajudicial confessions (exclusive television
interviews, as they both stipulated during pretrial) that they were indeed the perpetrators of the Valentine's Day
bombing.
- It is true that under the rule, statements made by a conspirator against a co-conspirator are admissible
only when made during the existence of the conspiracy.
- However, as the Court ruled in People v. Buntag, if the declarant repeats the statement in court, his
extrajudicial confession becomes a judicial admission, making the testimony admissible as to both
conspirators.
- Thus, in People v. Palijon, the Court held the following: …
- Distinction between extrajudicial and judicial confessions:
- An extrajudicial confession may be given in evidence against the confessant but not against his co-
accused as they are deprived of the opportunity to cross-examine him.
- A judicial confession is admissible against the declarant's co-accused since the latter are afforded
opportunity to cross-examine the former. Section 30, Rule 130 of the Rules of Court applies only to
extrajudicial acts or admissions and not to testimony at trial where the party adversely affected
has the opportunity to cross-examine the declarant .

People v. Alvarez, Jr.

Facts:
- The police in Camp Karingal, QC received an information that a dead body was found inside a taxicab. The police
officers went to the scene of the crime and learned that the deceased was Daniel Hernandez from the press
identification card found on him
- The police also found a fan knife, a .22 Beretta pistol, live ammunition, a diary and personal effects
- Meanwhile , in a seemingly unrelated incident, a certain Salvador Dizon carnapped a taxicab. The carnapped vehicle
was intercepted by the police officers and its driver. Salvador Dizon was killed during the shootout
- A . 38 Armscor revolver was found. The gun was submitted for a ballistic examination to determine whether it was
related to the killing of Hernandez
- After examination, it was found that the bullet recovered from Hernandez’ body was fired from the same .38 caliber
gun that was recovered from Dizon
- Police officers secured a warrant of arrest against appellant based on the information of his involvement in the robbery-
slay of Hernandez
- The prosecution presented the extrajudicial confession of appellant.
- Appellant narrated that Salvador Dizon (alias “Boy Polio”) was his friend and neighbor. One night, appellant was
asked to accompany Dizon for a drive. Along the way, DIzon told the appellant to disembark and hide himself inside
the baggage compartment of the taxicab, as was their modus operandi
- A passenger entered the taxicab. When the appellant went out of the trunk and was about to join the passenger who
was sleeping, the latter woke up and asked what was happening, then Dizon pointed a gun at him. Appellant
immediately ran away from the cab. Afterwards he heard a gunshot. Dizon caught up with appellant and told him to
get in the taxicab, where he saw the wounded passenger.

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 - Dizon and appellant looted the body of the passenger and divided the items among themselves.
- During the investigation, appellant identified the ring and watch of the victim as well as the taxicab they used in
committing the crime
- Appellant now denies the statements contained in his extrajudicial confession.
- He claimed that he was tortured by the policemen to force him to admit that he knew Dizon
- He alleged that investigators took his statement in the absence of a lawyer, despite his manifestation that he desired
to be assisted by a counsel of his own choice and that he was not allowed to read the statements which he was
forcible made to sign

Issue: Whether the extrajudicial confession of appellant was procured through force and violence hence inadmissible— No

Held:
- Appellant merely made self-serving testimonies—- appellant failed to present any evidence to prove that he was
tortured and intimidated into giving his extrajudicial confession
- Appellant did not show any physical marks to prove that he was tortured, neither did he identify any of the police
officers as his intimidators nor did he report the matter to his lawyer or to any of his relatives
- - Extrajudicial confessions are presumed voluntary, and, in the absence of conclusive evidence showing
the declarant’s consent in executing the same has been vitiated, such confession will be sustained
- In the present case, the testimonies of the police officers corroborated the declarations of the appellant in his
extrajudicial confession
- The sworn statement of appellant, as corroborated by the testimonies of the police officers in open court, are worthy
of credit, especially since the testimonies of the arresting officers who have no motive or reason to falsely testify in
regard to a serious charge against the appellant are credible
- Since the appellant’s confession is replete with details which he alone could have known and
supplied, thus indicating the voluntariness of its execution
- It was appellant himself who informed the police authorities of their modus operandi in holding up
their passengers. He described in detail the manner on how they killed and robbed their victim
- He was the one who disclosed where the victim’s ring and watch could be found which eventually led
to their recovery
- The voluntariness of a confession may be inferred from its being replete with details which could
possibly be supplied only by the appellant, reflecting spontaneity and coherence which cannot be said
of a mind on which violence and torture have been applied
- When the details narrated in an extrajudicial confession are such that they could not have been
concocted by one who did not take part in the acts narrated, where the claim of maltreatment in the
extraction of the confession is unsubstantiated and where abundant evidence exists showing that
the statement was voluntarily executed, the confession is admissible against the declarant
- There is greater reason for finding a confession to be voluntary where it is corroborated by evidence
aliunde which dovetails with the essential facts contained in such confession
- In the present case…
- The extrajudicial confession was taken in the presence not only of counsel, but also of radio and television reporters.
Appellant’s mother and wife’s nephew were also present and he even pointed to them in reference to some of his
answers during in court examination

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 - If appellant did not conform to the statements written by the police officer, he could not have signed the document
and requested that the same be changed to his satisfaction
- Since torture and intimidation has been ruled out, there is no other reason why appellant signed the confession
other than the fact that he affirmed the truth of the statements therein
- Even the appellant’s wife signed his extrajudicial confession, thus proving that said confession was executed
voluntarily and contained in essence of the appellant’s testimony

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