People v. Urminita
REITERATIONFacts
The Antecedents: In the evening of April 24, 1970, Pat. Reynaldo Reyes investigated a shooting incident at the corner of Cirma and Gen. Luna Streets, Sto. Nino, Marikina, where Felipe de los Reyes was found lying on the ground with gunshot wounds. Bystanders described the assailant. About an hour later, the accused, Efren Urminita y de Leon, surrendered to policemen, admitting he shot Felipe de los Reyes with a .38 caliber revolver, which he surrendered. Urminita gave a written statement admitting the shooting and stating it was planned. Felipe de los Reyes died on April 28, 1970, due to bronchopneumonia and peritonitis secondary to gunshot wounds. Ballistics examination confirmed the spent bullet was fired from the surrendered revolver. Procedural History: An information for Murder was filed against Efren Urminita y de Leon, alleging treachery and evident premeditation. The accused admitted shooting the victim but claimed self-defense, asserting he was hunted by the deceased and acted to protect himself. He also claimed his confession was coerced through a "water treatment." The trial court rejected the self-defense claim, finding the accused guilty of Murder and sentencing him to death. The court relied on the extrajudicial confession, corroborated by the corpus delicti, and found the accused's claims of maltreatment and self-defense not credible due to contradictions and lack of proof. The court also noted the accused's attempt to hide after the incident. The Petition: The accused appealed, arguing the trial court erred in refusing to believe his claim of self-defense, in giving credence to the prosecution witnesses (particularly Pat. Ricardo Mendoza, Jr.), and in giving weight to the alleged extra-judicial confession obtained by force and without counsel.
Issue(s)
Whether the accused acted in self-defense. Whether the trial court erred in giving credence to the prosecution witnesses, specifically Pat. Ricardo Mendoza, Jr. Whether the extra-judicial confession was admissible in evidence. Whether the accused is guilty of Murder and the appropriate penalty.
Ruling
The Supreme Court affirmed the conviction for Murder but modified the penalty from death to reclusion perpetua. The Court found that the accused failed to prove self-defense by clear and convincing evidence. The extrajudicial confession was deemed admissible and corroborated by the corpus delicti. The Court also found that the accused's claim of maltreatment was unsubstantiated and that the confession was obtained before the effectivity of the 1973 Constitution, making it admissible under the prevailing law. The presence of the mitigating circumstance of voluntary surrender offset the aggravating circumstance of evident premeditation, warranting the imposition of reclusion perpetua.
Ratio Decidendi
On the issue of self-defense: The Court held that the plea of self-defense must be proven by clear, convincing, and satisfactory evidence. The testimonies of the accused and his corroborating witness, Oscar Velardo, were found to be contradictory on material points, thus diminishing their probative value. Specifically, they differed on the number of shots fired by the accused and the victim's possession of two guns. The Court also found it improbable that the victim would recklessly place a loaded gun on his motorcycle. Furthermore, the accused's claim of being beaten in the presence of many people without intervention was deemed unbelievable, given the known status of both parties in the locality. The Court concluded that the records did not conclusively show that the accused was unlawfully assaulted by the deceased without provocation before the shooting. On the credibility of prosecution witnesses: The appellant assailed the credibility of Pat. Ricardo Mendoza, Jr., claiming bias because he testified that he did not know of other pending cases against the deceased. The Court found this argument unmeritorious, stating that Pat. Mendoza, as a mere police patrolman, cannot be expected to know every detail of the deceased's life or all pending cases against him. His lack of knowledge of other cases does not automatically prove bias or partiality, especially since the accused did not enumerate these alleged cases. The Court reiterated that regularity in the performance of official duties is presumed, and law enforcers should be given the benefit of the doubt. On the admissibility of the extra-judicial confession: The accused contended that his extra-judicial confession (Exhibit "E") was obtained by force and without the assistance of counsel, rendering it inadmissible. The Court noted that the allegation of maltreatment was uncorroborated, and the accused had not filed any administrative or criminal charges against his alleged tormentors. He admitted signing the "Salaysay" and affirmed the veracity of some statements within it. The Court found his claim of involuntariness unconvincing, especially since he did not affirm the confession when given the opportunity. The Court also applied the ruling in Magtoto vs. Manguera, stating that the constitutional mandate regarding the right to counsel in custodial investigations has prospective effect. Since the confession was obtained before the effectivity of the 1973 Constitution, it was admissible even if the accused was not informed of his right to counsel at that time. On the conviction for Murder and the appropriate penalty: The trial court correctly found the accused guilty of Murder, qualified by treachery, and attended by the generic aggravating circumstance of evident premeditation. The Court found that the accused employed a means that insured the execution of the crime without risk to himself. However, the Supreme Court modified the penalty from death to reclusion perpetua. This modification was based on the presence of the mitigating circumstance of voluntary surrender, as the accused peacefully surrendered to the police after the incident. This mitigating circumstance was deemed to offset the generic aggravating circumstance of evident premeditation. Therefore, reclusion perpetua was determined to be the proper penalty.
Main Doctrine
The penalty of death imposed for murder is modified to reclusion perpetua due to the presence of the mitigating circumstance of voluntary surrender, which offsets the aggravating circumstance of evident premeditation. An extrajudicial confession, if corroborated by evidence of corpus delicti, is sufficient for conviction. The admissibility of a confession obtained before the effectivity of the 1973 Constitution is governed by the law then in force, even if presented after its effectivity.