People v. Crisanto, Jr.
REITERATIONFacts
The Antecedents: Aurea Manaig-Hilario, an employee of the Commission on Audit, was stabbed in the back with a balisong knife while inside a jeepney. The assailant, who had alighted from another jeepney, approached her, stabbed her, left the knife embedded in her back, and fled. The victim was rushed to the hospital but was dead on arrival. The medico-legal officer determined the stab wound to be ten and a half centimeters deep, penetrating the left lung and pulmonary vein, and compatible with the knife found. Procedural History: The Regional Trial Court of Manila found Carlos Crisanto, Jr. and Celia Cruz guilty of murder, sentencing them to reclusion perpetua and ordering them to pay solidarily P256,272 in damages to the heirs of the victim. The accused appealed this decision. The Petition: The accused-appellants, Celia Cruz and Carlos Crisanto, Jr., contended that the trial court erred in giving credence to their extrajudicial confessions, which they repudiated during the trial, alleging they were secured through force, intimidation, and violation of their constitutional rights.
Issue(s)
Whether the extrajudicial confessions of the accused-appellants were admissible and properly given credence by the trial court. Whether the killing of Aurea Manaig-Hilario was attended by treachery (alevosia). Whether the penalty of reclusion perpetua was correctly imposed.
Ruling
The judgment of the trial court finding the accused-appellants guilty of murder and sentencing them to reclusion perpetua, with solidary payment of damages, is affirmed.
Ratio Decidendi
On the admissibility and credence of extrajudicial confessions: The Supreme Court held that there was no merit in the contentions of the accused-appellants that their confessions were obtained through force and intimidation. The factual finding of the trial court that the confessions were freely given was upheld and not disturbed. The testimonies of the police officers who took the confessions were given credence. The Court found that when Crisanto, a first-year college student, and Celia, a fourth-year high school student, swore to their confessions, they voluntarily, knowingly, and intelligently waived their constitutional rights to remain silent and to have counsel. The confessions were corroborated by evidence of corpus delicti. Even if the confessions were disregarded, the testimonies of the eyewitnesses (jeepney driver, his wife, and a passenger) were sufficient to prove the guilt of Carlos Crisanto beyond reasonable doubt. On the presence of treachery (alevosia): The Court affirmed that the killing was attended with treachery. The unexpected stabbing of the victim in the back, exhibiting the characteristic features of alevosia, demonstrated that the accused employed a mode of execution that insured the killing without any risk to himself, as the victim was unprepared and defenseless. This mode of attack directly led to the commission of the crime without any possibility of defense on the part of the victim. On the imposition of the penalty: The Court found no error in the trial judge's imposition of the penalty of reclusion perpetua for the murder. This penalty is the appropriate sentence for the crime of murder under the Revised Penal Code, considering the presence of aggravating circumstances such as treachery. Furthermore, the trial court properly took into account the victim's potential income in determining the civil liability, consistent with established jurisprudence.
Main Doctrine
Extrajudicial confessions, even if repudiated, are admissible and can be given credence if corroborated by evidence of corpus delicti and other evidence, and if the trial court found them to be voluntarily given. The killing was attended with treachery (alevosia) as the mode of execution insured the killing without risk to the perpetrator.