People v. Inguito
REITERATIONFacts
The Antecedents: The accused-appellant, Godofredo Inguito, along with co-accused Bienvenido Auguis and Salvador Petallino, were charged with murder for the killing of Epifanio Cajis on January 7, 1979. The information alleged that the accused conspired, confederated, and with superior strength and intent to kill, attacked and stabbed the victim with wooden sticks and a kitchen knife, causing mortal wounds that led to his death. Procedural History: The Court of First Instance of Baybay, Leyte, convicted all three accused and sentenced them to reclusion perpetua. Accused-appellant Godofredo Inguito appealed his conviction to the Court of Appeals, but the records were transmitted to the Supreme Court due to the penalty imposed. His co-accused failed to appeal. The Petition: The accused-appellant argued that his extra-judicial confession, which was the primary evidence against him, was obtained through force and intimidation, and in violation of his constitutional rights. He claimed he was mauled and threatened into signing the confession, and that he was not assisted by counsel during the investigation. He also contended that the remaining circumstantial evidence was insufficient to support a conviction.
Issue(s)
Whether the extra-judicial confession of the accused-appellant is admissible in evidence. Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant beyond reasonable doubt.
Ruling
The Supreme Court reversed the trial court's judgment of conviction and acquitted the accused-appellant Godofredo Inguito of the charge of murder. The Court ordered his immediate release unless held for another lawful cause.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Court held that the extra-judicial confession of the accused-appellant was null and void and inadmissible in evidence. The accused-appellant testified that he signed the confession because he was mauled in the toilet and warned by the escorting guard that he would be mauled again if he did not sign it after the judge read it. He also stated he was not represented by counsel and did not understand the contents of the affidavit, which was in English and he had not finished Grade One. The Court noted that the prosecution failed to present Patrolman Batoto to rebut the claim of mauling and threats. Furthermore, the confession was obtained in violation of the accused's constitutional rights to remain silent and to counsel, as mandated by Article IV, Section 20 of the 1973 Constitution. The Court emphasized that involuntary or coerced confessions are abhorred by law and are unreliable, standing discredited in the eyes of the law. On the sufficiency of circumstantial evidence: The Court found that without the inadmissible extra-judicial confession, the remaining evidence was weak circumstantial evidence. The testimony of Felimon de Veyra, the only witness presented by the prosecution to link the accused to the crime, was considered mere conjecture and purely circumstantial. De Veyra testified that he saw the accused drinking with the victim and later disappearing with him to an isolated place, but he did not actually see what they did to the victim. He only concluded they were the killers after the police took their statements. The Court reiterated that the presumption of innocence in favor of the accused must be overcome by proof beyond reasonable doubt, which requires moral certainty. The Court found no such proof in this case, as the circumstantial evidence did not produce moral certainty of the guilt of the accused.
Main Doctrine
Extra-judicial confessions obtained through force, intimidation, or in violation of the constitutional rights to remain silent and to counsel are null and void and inadmissible in evidence. Without such confession, weak circumstantial evidence cannot overcome the constitutional presumption of innocence.