Monday, May 27, 2019

[CASE DIGEST] People v. Maqueda (G.R. No. 112983)

March 22, 1995

Ponente: Davide, Jr., J.
 
FACTS:

·         Horace William Barker, a British consultant of the World Bank, and his Filipino wife Teresita Mendoza, lived in a country home in Tuba, Benguet together with two female househelps. 

·         On August 27, 1991, their former houseboy, Rene Salvamante, together with another man, broke into the Barkers' home. Using lead pipes, the two men attacked members of the household, leaving the two female househelps wounded, Teresita badly injured, and Horace dead. The two men also ransacked the property, taking away valuables with an aggregate cost of P204,250. Items stolen included Teresita's Canon camera, radio casette recorder, and pieces of jewelry.

·         A certain Richard Malig was arrested as Salvamante's supposed co-conspirator, but his name was subsequently dropped from the Information because further evaluation of the evidence disclosed no sufficient evidence against him. 

·         Subsequently, the Information was amended to implead Hector Maqueda alias "Putol" because the evaluation of the evidence submitted established his complicity in the crime. He was identified by the witnesses on account of his amputated left hand and a right hand with a missing thumb and index finger, hence his alias. 

·         Maqueda was arrested in 1992. In his Sinumpaang Salaysay, he narrated his participation in the crime at the Barker house on August 27, 1991.

·         While he was under detention, Maqueda filed an application for bail where he categorically stated that he was willing and volunteering to be a State witness in the case, it appearing that he was the least guilty among the accused. Prosecutor Daniel Zarate then had a talk with Maqueda regarding such statement and asked him if he was in the company of Salvamante on the date of the crime in entering the house of the Barkers. After he received an affirmative answer, Prosecutor Zarate told Maqueda that he would oppose the motion for bail since he, Maqueda, was the only accused on trial since Salvamante remained at large.

·         In the meantime, Ray Dean Salvosa, executive vice president of the Baguio College Foundation, arrived at the office of Prosecutor Zarate and obtained permission from the latter to talk to Maqueda. Salvosa then led Maqueda toward the balcony. Maqueda narrated to Salvosa that Salvamante brought him to Baguio City in order to find a job as a peanut vendor; Salvamante then brought him to the Barker house and it was only when they were at the vicinity thereof that Salvamante revealed to him that his zeal purpose in going to Baguio City was to rob the Barkers; he initially objected to the plan, but later on agreed to it; when they were in the kitchen of the Barker house, one of the househelps was already there; Salvamante hit her with a lead pipe and she screamed; then Mrs. Barker came down, forcing him, Maqueda, to attack her with the lead pipe provided·him by Salvamante, After he felled Mrs. Barker, he helped Salvamante in beating up Mr. Barker who had followed his wife downstairs. the Barkers were already unconscious on the' floor, Salvamante went upstairs and a few minutes later came down bringing with him a radio cassette and some pieces of jewelry.

·         Maqueda further divulged to Salvosa that they then changed clothes, went out of the house, walked toward the road where they Saw two persons from whom they asked directions, and when a passenger jeepney stopped and they were informed by the two Persons that it was bound for Baguio City, he and Salvamante bearded it. They alighted somewhere along Albano Street in Baguio City and walked until they reached the Philippine Rabbit Bus station where they boarded a bus for Manila.

·         During the trial, Maquedo denied any involvement in the crime. Instead, he interposed an alibi, saying he was in Muntinlupa working at a polvoron factory at the time the crime against the Barkers was committed. This was, however, disproved by circumstantial evidence showing he was not working at a polvoron factory at the time. 

·         Although the trial court had doubts on the identification of Maqueda by Teresita and the two female househelps, and thus disregarded their testimonies on this matter, it nonetheless decreed a conviction based on Maqueda's confession and the proof of corpus delict, as well as on circumstantial evidence.*

·         The trial court found Maqueda guilty beyond reasonable doubt of the crime of robbery with homicide and serious physical injuries and sentenced him to suffer the penalty of reclusion perpetua and to indemnify the victim, Teresita, in the amount of P50,000.00 for the death of William Horace Barker.

·         Hence, the instant petition.

RULING:  

Petition denied.




Whether Maqueda's Sinumpaang Salaysay where he recounted his involvement in the crime constituted an extrajudicial confession. – NO.

·         Maqueda's Sinumpaang Salaysay is not an extrajudicial confession but an extrajudicial admission. There is a distinction between the former and the latter as clearly shown in Sections 26 and 33, Rule 130 of the Rules of Court. In a confession, there is an acknowledgment of guilt. The term admission is usually applied in criminal cases to statements of fact by the accused which do not directly involve an acknowledgment of his guilt or of the criminal intent to commit the offense with which he is charged.
·         According to Wharton: "A confession is an acknowledgment in express terms, by a party in a criminal case, of his guilt of the crime charged, while an admission is a statement by the accused, direct or implied, of facts pertinent to the issue and tending, in connection with proof of other facts, to prove his guilt. In other words, an admission is something less than a confession, and is but an acknowledgment of some fact or circumstance which in itself is insufficient to authorize a conviction and which tends only to establish the ultimate fact of guilt."

·         Under Section 3 of Rule 133, an extrajudicial confession made by the accused is not sufficient for conviction unless corroborated by evidence of corpus delicti.


Whether Maqueda's extrajudicial admission in his Sinumpaang Salaysay admissible as evidence. – NO.

·         The Sinumpaang Salaysay of Maqueda taken by SP02 Molleno after the former's arrest was taken in palpable violation of his rights under Section 12(1), Article III of the Constitution. As disclosed by a reading thereof, Maqueda was not even told of any of his constitutional rights under the said section. The statement was also taken in the absence of counsel. Such uncounselled Sinumpaang Salaysay is wholly inadmissible pursuant to paragraph 3, Section 12, Article III of the Constitution which reads: "Any confession or admission obtained in violation of this or Section 17 hereof shall be inadmissible in evidence against him."

·         The trial court erred in admitting Maqueda's Sinumpaang Salaysay as evidence despite knowing that it was taken without the assistance of counsel. The right to be heard would be a farce if it did not include the right to counsel. The present Constitution provides that in all criminal prosecutions the accused shall enjoy the right to be heard by himself and counsel.

·         The trial court was also out of line when it held that since an information had already been filed in court against Maqueda and he was arrested pursuant to a warrant of arrest issued by the court, the Sinumpaang Salaysay was not, therefore, taken during custodial investigation. The exercise of the rights to remain silent and to counsel and to be informed thereof under Section 12(1), Article III of the Constitution are not confined to that period prior to the filing of a criminal complaint or information but are available at that stage when a person is "under investigation for the commission of an offense." 

·         It was, therefore, wrong for the trial court to hold that Section 12(1), Article III of the Constitution is strictly limited to custodial investigation and that it does not apply to a person against whom a criminal complaint or information has already been filed because after its filing he loses his right to remain silent and to counsel. If we follow the theory of the trial court, then police authorities and other law enforcement agencies would have a heyday in extracting confessions or admissions from accused persons after they had been arrested but before they are arraigned because at such stage the accused persons are supposedly not entitled to the enjoyment of the rights to remain silent and to counsel.

·         The trial court likewise erred when it held that Section 12(1), Article III** of the Constitution was not applicable since the police investigation was "no longer within the ambit of a custodial investigation."
·         And finally, the trial court erred in declaring that the admissibility of the Sinumpaang Salaysay should not be tested under Section 12(1), Article III of the Constitution, but on the voluntariness of its execution. It was wrong for the trial court to rule that since voluntariness was presumed, Maqueda had the burden of proving otherwise, which he failed to do and, hence, the Sinumpaang Salaysay was admissible against him.

·         In sum, the subject Sinumpaang Salaysay should not have been admitted as evidence.





Whether Maqueda's verbal admissions to Prosecutor Zarate and Ray Dean Salvosa are admissible as evidence. – YES.

·         Maqueda's extrajudicial admissions to Zarate and Salvosa are not governed by the exclusionary rules under the Bill of Rights. Maqueda voluntarily and freely made them to Prosecutor Zarate not in the course of an investigation, but in connection with Maqueda's plea to be utilized as a state witness; and as to the other admission, it was given to a private person. 

·         The provisions of the Bill of Rights are primarily limitations on government, declaring the rights that exist without governmental grant, that may not be taken away by government and that government has the duty to protect;  or restriction on the power of government found "not in the particular specific types of action prohibited, but in the general principle that keeps alive in the public mind the doctrine that governmental power is not unlimited.  They are the fundamental safeguards against aggressions of arbitrary power, or state tyranny and abuse of authority. In laying down the principles of the government and fundamental liberties of the people, the Constitution did not govern the relationships between individuals. 

·         Accordingly, Maqueda's admissions to Ray Dean Salvosa, a private party, are admissible in evidence against the former Under Section 26, Rule 130 of the Rules of Court. The declaration of an accused expressly acknowledging his guilt of the offense may be given in evidence against him and any person, otherwise competent to testify as a witness, who heard the confession, is competent to testify as to the substance of what he heard if he heard and understood it. The said witness need not repeat verbatim the oral confession; it suffices if he gives its substance. By analogy, that rule applies to oral extrajudicial admissions.

·         To be added to Maqueda's extrajudicial admission is his Urgent Motion for Bail wherein he explicitly .stated that "he is willing and volunteering to be a state witness in the above entitled case, it appearing that he is the least guilty among the accused in this case."
·         In the light of his admissions to Prosecutor Zarate and Ray Dean Salvosa and his willingness to be a state witness, Maqueda's participation in the commission of the crime charged was established beyond moral certainty.


Whether Maqueda's conviction should be sustained. – YES.

·         Even if the Court disregard his extrajudicial admissions to Prosecutor Zarate and Salvosa, Maqueda's guilt was, as correctly ruled by the trial court, established beyond doubt by circumstantial evidence. 

·         Section 4, Rule 133 of the Rules of Court provides that circumstantial evidence is sufficient for conviction if: (a)There is more than one circumstance; (b) The facts from which the inferences are derived are proven; and (c) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

·         As jurisprudentially formulated, a judgment of conviction based on circumstantial evidence can be upheld only if the circumstances proved constitute an unbroken chain which leads to one fair and reasonable conclusion which points to the accused, to the exclusion of all others, as the guilty person, i.e. the circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with any other hypothesis except that of guilty.

·         The following circumstances were duly proved in this case:
  1. He and a companion were seen a kilometer away from the Barker house an hour after the crime in question was committed there;
  2. Rene Salvamante, who is still at large, was positively identified by Mrs. Barker, Norie Dacara, and Julieta Villanueva as one of two persons who committed the crime;
  3. He and co-accused Rene Salvamante are friends;
  4.  He and Rene Salvamante were together in Guinyangan, Quezon, and both left the place sometime in September 1991;
  5. He was arrested in Guinyangan, Quezon, on 4 March 1992; and
  6. He freely and voluntarily offered to be a state witness stating that "he is the least guilty."