Peter Paul Aballe y Mendoza v. People of the Philippines
REITERATIONFacts
The Antecedents: On November 7, 1980, at around 7:00 PM, Quirino Banguis attended a birthday party, leaving his 12-year-old daughter, Jennie, alone at home. Upon returning at 8:30 PM, he found Jennie lying in the sala, covered in blood, with multiple wounds. There were no eyewitnesses to the killing. The postmortem report indicated 32 stab wounds, with death caused by hemorrhage secondary to multiple stab wounds. Procedural History: The following day, November 8, 1980, police, acting on information from the victim's father, apprehended Peter Paul Aballe, then 17 years old, as he was emerging from a communal bathroom, wearing a bloodstained T-shirt. Aballe spontaneously confessed to killing Jennie. He was brought to the police station for interrogation, where he made an extrajudicial confession admitting guilt, claiming he acted under the influence of liquor and marijuana after the victim slapped him for waking her up. He also led the police to the hidden murder weapon, a kitchen knife, and the bloodstained T-shirt. An information for homicide was filed. Aballe pleaded not guilty and disavowed his confession, alleging coercion and absence of counsel. The trial court convicted him of homicide. The Petition: Aballe appealed, arguing that his extrajudicial confession and the recovered weapon were inadmissible due to violations of his constitutional rights, and that the imposed penalty was incorrect.
Issue(s)
Whether the extrajudicial confession of the accused, Peter Paul Aballe, is admissible in evidence, and whether the kitchen knife and bloodstained T-shirt are admissible as evidence. Whether the oral confession of the accused, Peter Paul Aballe, is admissible in evidence. Whether the accused Peter Paul Aballe is guilty of homicide. Whether the penalty imposed on the accused is in accordance with law, considering his minority and the presence of mitigating and aggravating circumstances.
Ruling
The Court affirmed the conviction for homicide but modified the penalty. The extrajudicial confession and the kitchen knife were declared inadmissible. However, the oral confession made spontaneously to Sgt. Marante was deemed admissible. The Court found the accused guilty based on the oral confession and the bloodstained T-shirt. The penalty was modified to an indeterminate sentence of six (6) years of prision correccional as minimum to twelve (12) years of prision mayor as maximum. The civil indemnity was increased to P30,000.00.
Ratio Decidendi
On the admissibility of the extrajudicial confession and the kitchen knife: The Court held that the extrajudicial confession, sworn to during custodial investigation, was inadmissible because it was obtained in violation of Aballe's constitutional rights. Specifically, the waiver of counsel was not made with the assistance of counsel, as mandated by Section 20, Article IV of the 1973 Constitution. Consequently, the kitchen knife, recovered as a fruit of this constitutionally infirm interrogation, was also deemed inadmissible. The Court emphasized that the confession and the weapon were products of a procedurally flawed investigation and must be excluded from evidence. On the admissibility of the oral confession and the bloodstained T-shirt: The Court ruled that Aballe's spontaneous oral confession to Sgt. Marante, made as he was emerging from the bathroom and before any custodial interrogation commenced, was admissible. This spontaneous declaration was not elicited through questioning and thus did not fall under the strictures of custodial investigation. The bloodstained T-shirt was also admissible as evidence in plain view, which an arresting officer may seize and introduce in evidence. The Court cited the rule that an officer making an arrest may take from the person arrested any property used in the commission of the crime or which may be used in evidence. On the guilt of the accused: Despite the exclusion of the extrajudicial confession and the knife, the Court agreed with the trial court that the guilt of the accused was established beyond reasonable doubt. This was primarily based on the admissible spontaneous oral confession made to Sgt. Marante, which positively linked Aballe to the killing. The testimony of Sgt. Marante regarding this confession was considered competent evidence. The presence of the bloodstained T-shirt further corroborated the oral admission. On the penalty and circumstances: The Court found that the killing of Jennie was mitigated by the accused's minority, as he was 17 years old at the time of the offense. However, it was aggravated by dwelling, as the victim was killed in her parents' house. Since dwelling was not alleged in the information, it was considered a generic aggravating circumstance and could not offset the privileged mitigating circumstance of minority. The penalty for homicide is reclusion temporal. Applying the Indeterminate Sentence Law and considering the privileged mitigating circumstance of minority, the penalty next lower than reclusion temporal was imposed in its maximum period, resulting in an indeterminate sentence of six (6) years of prision correccional as minimum to twelve (12) years of prision mayor as maximum. The civil indemnity was increased to P30,000.00.
Main Doctrine
An extrajudicial confession obtained in violation of the constitutional rights of the accused, specifically the right to counsel during custodial investigation and the right to have any waiver of such rights made with the assistance of counsel, is inadmissible in evidence. However, a spontaneous oral confession made to an arresting officer, not elicited through questioning, is admissible as it does not fall under custodial investigation.