People v. Gavarlan
REITERATIONFacts
The Antecedents: The remains of Susana de Ocampo were found in a dry creek bed, two weeks after she had been reported missing. A scarf was tied tightly around her neck, and a patadion enveloped her body below the waist. Her cousin identified the scarf and patadion as belonging to the deceased. Procedural History: The accused, Policarpo Gavalan, was suspected of the murder, arrested, and made a full confession to police officers and the chief of police. He pleaded guilty during the preliminary investigation. The Court of First Instance of Iloilo convicted him of murder and sentenced him to life imprisonment. The Petition: The accused appealed the decision of the lower court.
Issue(s)
Whether the crime committed was murder qualified by treachery. Whether the accused's confession should be accepted in its entirety.
Ruling
The Supreme Court modified the judgment of the lower court, convicting the accused of homicide instead of murder. The accused was sentenced to fourteen years, eight months, and one day of reclusion temporal, to indemnify the heirs of the deceased in the sum of P1,000, and to pay the costs of the trial.
Ratio Decidendi
On the issue of whether the crime committed was murder qualified by treachery: The Court held that the crime was homicide, not murder qualified by treachery. The only evidence presented regarding the manner of death was the accused's confession. The Court found that the confession did not disclose any attributes of treachery, as the death of Susana de Ocampo was accomplished under an agreement between the two that her life should be taken. The Court emphasized that as a general rule, one part of a confession cannot be taken and the other part rejected unless there are proofs in the record that justify such a course. While the accused's story had some marks of improbability, there was nothing substantial in the case to justify accepting one portion of the confession and rejecting the balance. Therefore, the qualifying circumstance of alevosia (treachery) was not proven. On the issue of whether the accused's confession should be accepted in its entirety: The Court ruled that the confession must be accepted in its entirety. The Court stated that as a general rule, one part of a confession cannot be taken and the other part rejected unless there are proofs in the record which justify such a course. The confession detailed the events leading to the death, including the agreement between the accused and the deceased for her death and the method used. The Court found no substantial evidence in the record to justify rejecting the portion of the confession that indicated the death was consensual or agreed upon, even if other parts of the confession might seem improbable. The confession was corroborated by the finding of the body in the location described, the scarf tied around the neck, and the manner of death.
Main Doctrine
A confession, even if it contains improbable elements, must be accepted in its entirety unless there are proofs in the record that justify the rejection of a portion thereof. The crime of murder cannot be qualified by treachery when the death was accomplished under an agreement between the victim and the accused.