People v. Clores
REITERATIONFacts
The Antecedents: On December 20, 1971, Jaime Clores and Mario Holiday, both patients in Ward VI of the New Bilibid Prisons Hospital, entered Ward V where the victim, Bayani Salido, was confined. Clores, with Salido's back towards him, suddenly stabbed Salido at the shoulder. Almost simultaneously, Holiday approached Benito Satorre, an attendant-helper, and stabbed him twice. Satorre defended himself with a piece of wood, causing Holiday to retreat. Clores and Holiday then fled to Ward VI. Dr. Ricardo de Vera found Salido pulseless and ordered his transfer to the emergency room. Clores surrendered himself and the weapon to the PC. Both appellants gave written statements, as did Satorre and Melencio Canin. Procedural History: The Circuit Criminal Court in Rizal imposed the death penalty on Jaime Clores and Mario Holiday for murder and attempted murder as a complex crime under Article 48 of the Revised Penal Code. They were ordered to indemnify the heirs of Bayani Salido and pay moral and exemplary damages. Although Clores pleaded guilty, the trial court ordered the presentation of evidence. The court found the crimes to be a complex crime and imposed the maximum penalty of murder. The Petition: The case was under automatic review by the Supreme Court. Appellants argued that their statements were involuntarily given due to violence and maltreatment, and that the evidence was insufficient to prove conspiracy, murder, or attempted murder.
Issue(s)
Whether the confessions of the appellants were voluntarily given and admissible in evidence. Whether the killing of Bayani Salido and the stabbing of Benito Satorre constituted murder and attempted murder, respectively, as a complex crime, and whether conspiracy between Jaime Clores and Mario Holiday was sufficiently established. Whether the qualifying circumstances of treachery and evident premeditation were present. Whether Mario Holiday is guilty of attempted murder. On the penalty and indemnity.
Ruling
The Supreme Court modified the decision of the trial court. Jaime Clores was found guilty of homicide only, not murder, and sentenced to an indeterminate sentence of 12 years of prision mayor to 20 years of reclusion temporal. The indemnity for the heirs of Bayani Salido was increased to P12,000.00. Mario Holiday was acquitted of the charges of murder and attempted murder.
Ratio Decidendi
On the admissibility of confessions: The Supreme Court found that the confessions of both appellants were inadmissible in evidence due to violence and maltreatment. Dr. Zoraida Achazo Ocampo testified that Jaime Clores suffered physical injuries consistent with a blow from a blunt instrument, corroborating his claim of being beaten into unconsciousness. Mario Holiday also testified to being maltreated with "karate" blows and treated for a cut on the head. The Court noted the failure of the prosecution to present delas Alas, who was accused of inflicting the severe beating on Clores, to rebut the appellants' testimonies. This finding of violence rendered the supposed confessions extorted and thus inadmissible. On the existence of a complex crime and conspiracy: With the exclusion of the confessions, the Supreme Court found an utter insufficiency of evidence to establish conspiracy. The trial court's finding of conspiracy, based solely on the supposed confessions and the observation that the accused "have agreed to kill anybody or somebody who belonged to their rival gang," was deemed erroneous. The manner of the killing did not suggest gang rivalry, especially since one of the alleged victims, Benito Satorre, did not belong to any gang. The Court found the testimony of Holiday, who claimed he did not attack Satorre and merely approached him to buy cigarettes, to be more credible than Satorre's account of being attacked, particularly since Satorre admitted no motive for Holiday to attack him and Holiday failed to inflict any injury despite Satorre being asleep. On the qualifying circumstances of treachery and evident premeditation: The Supreme Court ruled out treachery. According to Clores' testimony, which the Court found more credible, the stabbing was made frontally, not from behind as Satorre declared. Satorre's testimony was deemed unreliable as he claimed to have seen Clores stab Salido while he was busy defending himself from Holiday. The location of the wounds also suggested an attack from the front. Evident premeditation was also ruled out, as there was no lapse of time during which Clores meditated on the consequences of his act and clung to his determination to commit the crime. The Court noted that the trial court made no finding on evident premeditation and erred in finding the crimes to be a complex crime. On the conviction for homicide and acquittal of attempted murder: Holiday was acquitted of attempted murder because his alleged assault against Satorre was not proven beyond reasonable doubt. Satorre's testimony was found to be not credible, and Holiday's explanation of approaching Satorre to buy cigarettes was deemed more believable. The Court concluded that the stabbing was motivated by a strictly personal reason on the part of Clores, excluding conspiracy with Holiday. On the penalty and indemnity: For the crime of homicide, the Supreme Court imposed the maximum penalty of 20 years of reclusion temporal due to the aggravating circumstance of serving sentence when the crime was committed. The indemnity for the heirs of the deceased was increased from P10,000.00 to P12,000.00, consistent with prevailing jurisprudence.
Main Doctrine
Confessions obtained through violence and maltreatment are inadmissible in evidence. Without such confessions, the prosecution failed to establish conspiracy and the qualifying circumstances of murder and attempted murder beyond reasonable doubt, leading to conviction for homicide only for the principal offender and acquittal for the co-accused.