People v. Nolasco
REITERATIONFacts
The Antecedents: On July 21, 1979, at around 10:00 PM, Carmelita Contapay-Bacay and her sister Lilia Contapay-Laguitan were sleeping in their pushcarts outside their residence in Tondo, Manila. Two men approached; one stabbed Carmelita three times while she was asleep. Lilia shouted a warning but to no avail. Carmelita died en route to the hospital. Lilia identified the accused, Mauricio Nolasco, to the police hours later. The accused was apprehended on October 11, 1979, and positively identified by Lilia on October 17, 1979. On October 18, 1979, the accused executed a sworn extrajudicial confession admitting the stabbing. He was charged with murder. Procedural History: The Circuit Criminal Court of Manila convicted the accused of murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of the victim. The accused appealed, claiming his extrajudicial confession was involuntary due to physical maltreatment. The Petition: The accused-appellant maintained that the trial court erred in convicting him based on an involuntary extrajudicial confession and prayed for his acquittal.
Issue(s)
Whether the extrajudicial confession of the accused is admissible in evidence. Whether, despite the inadmissibility of the confession, the guilt of the accused for the crime of murder has been established beyond reasonable doubt by other evidence, and the determination of the appropriate crime and penalty.
Ruling
The Supreme Court modified the appealed judgment. While the extrajudicial confession was declared inadmissible due to violations of the accused's constitutional rights, his guilt was established by other evidence, specifically the positive identification by the victim's sister. The penalty was modified to an indeterminate sentence, and the indemnity to the heirs was increased.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Supreme Court agreed with the appellant that the trial court erred in admitting the extrajudicial confession. Even if the appellant failed to substantiate his claim of maltreatment, the confession was inadmissible because the accused was deprived of his constitutional rights under Section 20 of Article IV of the 1973 Constitution. Specifically, while the accused waived his right to counsel, the waiver was not shown to be voluntary, knowing, and intelligent, nor was it made in the presence of his lawyer, which defect nullifies the confession's admissibility. The Court emphasized that a waiver of the right to counsel must be made with the assistance of a lawyer. On the guilt of the accused established by other evidence, the crime committed, and penalty: Despite the inadmissibility of the confession, the accused's guilt was established beyond reasonable doubt by other evidence. The victim's sister, Lilia Contapay-Laguitan, positively identified the accused in open court as the perpetrator. The Court found Lilia's identification credible, noting that she had known the accused for years, had seen him participate in riots in the vicinity, and the crime scene was well-illuminated, making misidentification unlikely. The defense of alibi was rejected as it was not physically impossible for the accused to be at the scene of the crime, which was within walking distance of his residence. The alleged ill-motive of Lilia was deemed too conjectural and flimsy to warrant belief. The offense committed was murder, qualified by treachery, as the victim was attacked while asleep and defenseless. The trial court correctly imposed the penalty of reclusion perpetua. However, considering the abolition of capital punishment and the provisions of the 1987 Constitution, the penalty for murder is now reclusion temporal in its maximum period to reclusion perpetua. In the absence of modifying circumstances, the penalty is imposed in its medium period. The Court also applied the Indeterminate Sentence Law, setting the minimum penalty at ten (10) years and one (1) day of prision mayor and the maximum at eighteen (18) years, eight (8) months and one (1) day of reclusion temporal. The indemnity to the heirs was increased from P12,000.00 to P30,000.00.
Main Doctrine
An extrajudicial confession obtained in violation of the constitutional rights of the accused, specifically the right to counsel and the prohibition against compulsion, is inadmissible in evidence. However, guilt can still be established by other evidence, such as positive identification by a credible witness.