People v. Reunir
REITERATIONFacts
The Antecedents: On December 4, 1983, at around 9:00 PM, the victim, Alejandro Reunir y Tan (accused-appellant), Dominador Umagtang (victim's father), and Felix Ramos, Jr. (nightshift driver) were together. The accused asked for money from the victim twice; the first time it was given, but the second time it was refused, which the accused resented. The accused also got angry at Felix Ramos, Jr. for not having money. The victim then went to sleep in a house in front of the memorial chapels' basement. At around 1:00 AM on December 5, 1983, Felix Ramos, Jr. saw the accused enter the house where the victim was sleeping. The accused was the only person inside with the victim. When the accused exited, Felix Ramos, Jr. saw him with a kitchen knife. Felix Ramos, Jr. and the janitor brought the victim to the hospital. On the way, the victim stated he did not know who stabbed him as he was sleeping. The victim died on the same day due to shock and hemorrhage from a stab wound. The victim was 17 years old and lost earning capacity. The accused was arrested on February 27, 1984, and made several statements admitting to the killing, claiming it was in self-defense. Procedural History: The Regional Trial Court of Quezon City convicted the accused-appellant of Murder and sentenced him to reclusion perpetua, to indemnify the heirs, and to pay costs. The accused-appellant appealed. The Petition: The accused-appellant argued that the RTC erred in convicting him based on an inadmissible confession (Exhibit A) and in giving credence to the testimony of Felix Ramos, Jr.
Issue(s)
Whether the extrajudicial confession (Exhibit A) is admissible in evidence. Whether the other extrajudicial confessions (Exhibits D and E) are admissible in evidence. Whether the testimony of the prosecution witness, Felix Ramos, Jr., is credible; Whether motive and flight of the accused-appellant are indicative of guilt; Whether the defense of alibi is tenable. Whether treachery attended the commission of the crime. Whether the guilt of the accused-appellant was established beyond reasonable doubt; On the penalty.
Ruling
The appealed judgment is modified. The accused-appellant, Alejandro Reunir y Tan, is sentenced to suffer the indeterminate penalty of ten (10) years and one (1) day of prision mayor, as minimum, to eighteen (18) years, eight (8) months and one (1) day of reclusion temporal, as maximum. Costs against the accused-appellant.
Ratio Decidendi
On the admissibility of Exhibit A: The Court found merit in the first assigned error. Exhibit A, an extrajudicial confession, was deemed inadmissible because it was extracted from the accused-appellant while he was alone among military officers without a lawyer to assist him. The Court reiterated that conviction cannot be based on such an inadmissible confession. On the admissibility of Exhibits D and E: The Court also held that Exhibits D and E, two other extrajudicial confessions, were similarly inadmissible. Although the accused-appellant's mother was a witness to Exhibit D, her presence did not satisfy the constitutional requirement for the presence of counsel during custodial interrogations to safeguard the detained person's rights. The Court cited Morales, Jr. vs. Enrile in support of this ruling. On the credibility of Felix Ramos, Jr.'s testimony and circumstantial evidence; On the motive and flight of the accused-appellant; On the defense of alibi: Despite the inadmissibility of the confessions, the Court found that the circumstantial evidence was ample to establish the guilt of the accused-appellant. The prosecution witness, Felix Ramos, Jr., testified that he saw the accused-appellant enter the house where the victim slept and later leave with a kitchen knife. The victim was found with a stab wound, and no one else was in the house with the victim. The Court found no inconsistency in the witness's testimony and affirmed the RTC's credence to it. The Court established motive, which was the victim's refusal to lend money to the accused-appellant for the second time. The flight of the accused-appellant to Quezon Province after the incident was also considered indicative of guilt. His explanation for leaving was deemed too flimsy to justify his absence. The Court rejected the defense of alibi, stating that for it to succeed, it must be shown that it was physically impossible for the accused-appellant to have been at the scene of the crime. The distance between the Metro-aide quarters and the memorial chapels was considered negligible, making it possible for the accused-appellant to have committed the offense and returned. On the appreciation of treachery: The Court correctly appreciated treachery. The victim's statement to Felix Ramos, Jr. that he did not know who stabbed him because he was asleep was considered part of the res gestae and sufficiently proved that treachery attended the commission of the offense, as the victim was attacked while asleep. On the guilt of the accused-appellant; On the penalty: The Court modified the penalty. With the abolition of capital punishment, the penalty for Murder is now reclusion temporal in its maximum period to reclusion perpetua. Applying the Indeterminate Sentence Law, the penalty was imposed in its medium period, with the indeterminate penalty ranging from prision mayor to reclusion temporal.
Main Doctrine
Extrajudicial confessions obtained during custodial interrogation without the presence of counsel are inadmissible in evidence. However, conviction may be based on circumstantial evidence and other admissible confessions if they are sufficient to establish guilt beyond reasonable doubt. Treachery may be appreciated based on the victim's dying declaration forming part of the res gestae.