People v. Damaso
REITERATIONFacts
The Antecedents: Victoriano Damaso, Juanito Favie, Jr., and Reynaldo Calpo were drinking at "Aling Meding's Carinderia." A confrontation arose when Damaso poured beer on Roberto Villalino, who then slapped Damaso. The situation was pacified, but Damaso warned the other group, "Pare, hintay kayo, babalik kami." Subsequently, the three accused borrowed a carbine from a security guard, Charles Miane, after which they returned to the carinderia in a taxi. From the speeding taxi, Reynaldo Calpo fired shots, hitting Roberto Villalino and Alfredo Antiporda, Jr., who died, and Edmundo Relova, who was wounded. Procedural History: The trial court (CFI of Rizal) found Victoriano Damaso alias Rogelio Damaso, Reynaldo Oliveros Calpo, and Juanito P. Favie, Jr. guilty beyond reasonable doubt of Murder (Cases 6934 & 6935) and Frustrated Murder (Case 6936). They were sentenced to reclusion perpetua for the murders and an indeterminate penalty for frustrated murder, with civil indemnities. Only Victoriano Damaso and Juanito Favie, Jr. appealed. Juanito Favie, Jr. later withdrew his appeal. The Petition: Victoriano Damaso alias Rogelio Damaso appealed the decision, raising several errors, primarily concerning the admissibility of his extrajudicial confession, the existence of conspiracy, the trial court's appreciation of evidence, and the classification of his culpability.
Issue(s)
Whether the extra-judicial confessions of the appellants were obtained by force and intimidation and thus inadmissible as evidence. Whether the trial court erred in finding that the appellants conspired with Reynaldo Calpo in the killing of Alfredo Antiporda and Roberto Gilber and in the assault of Edmundo Relova. Whether the trial court erred in finding that the flight of the appellants was an indication of their guilt. Whether the appellants should be held culpable as accomplices, not principals. Whether the trial court erred in not considering the non-rebuttal of the versions of the appellants by the prosecution. Whether the trial court erred in not considering the return of Damaso to the scene of the crime a few hours after the incident as an indication of his lack of complicity. Whether the trial court erred in not holding appellants as merely conspirators to scare the Antiporda group.
Ruling
The Supreme Court affirmed the decision of the trial court in toto, with the modification that the indemnities for the death of Roberto Villalino y Gilber and Alfredo Antiporda, Jr. were increased to P50,000.00 each.
Ratio Decidendi
On the admissibility of extra-judicial confessions: The Court held that the extrajudicial confessions of Damaso and Favie were given freely and voluntarily. Despite claims of force and intimidation, the confessions contained details only the accused could supply, lending them credence. The Court noted the presumption of regularity in the performance of duty by the investigator and the lack of proof of coercion. The claims of using a false name for the gun source and the denial of sister's visitation were found untenable or unsubstantiated. The Court reiterated that bare assertions of maltreatment are insufficient without corroborating evidence, and the confessions, executed before the 1987 Constitution, were admissible even without counsel. On the existence of conspiracy: The Court found that conspiracy existed among the three accused, evidenced by their unity of purpose and action. Circumstantial evidence, including the slapping incident, Damaso's threat to return, their joint act of borrowing a carbine, their return to the scene in a taxi, the shooting from the taxi, and their subsequent actions, all pointed to a common design. The Court emphasized that conspiracy can be established by circumstantial evidence and that conspirators are equally responsible for the acts of their co-conspirators. On the flight of the appellants: The Court ruled that the flight of the accused was an indication of their guilty conscience. Damaso's claim of hiding due to a shoot-to-kill order was not substantiated by the witness. The Court found it more logical for an innocent person to cooperate with authorities rather than flee. The Court reiterated the established principle that flight is an indication of guilt, and even the contrived reason of fear of Martial Law could not overturn this aphorism. On the classification of culpability (Principals vs. Accomplices): The Court held that Damaso was liable as a principal by reason of conspiracy. Since conspiracy was established, Damaso was equally responsible for the acts of his co-accused, Reynaldo Calpo, who fired the shots. The Court cited the principle that all those who participated in the conspiracy are liable for the crimes committed. On the non-rebuttal of defense versions: The Court found no need for rebuttal as the defense's versions were discredited by the trial court for being against human nature and experience. The Court gave more credence to the positive evidence of the prosecution over the negative evidence of the defense. The Court also noted that a witness's testimony can be believed in part and disbelieved in part. On Damaso's return to the scene: The Court found Damaso's return to the scene not indicative of innocence but rather an attempt to ascertain the extent of the damage caused. His subsequent flight after learning of the fatalities further underscored his guilty conscience, as an innocent person would have stayed to cooperate with authorities. On the intent to merely scare: The Court rejected the defense's claim that the intention was merely to scare the victims. This was belied by the use of a carbine, the accuracy of the shots, and the gravity of the wounds. Even if the intention was to scare, firing at the victims was an unlawful act, and the accused are responsible for the natural and logical consequences of their actions.
Main Doctrine
Conspiracy among the accused in the commission of the crime renders each conspirator equally responsible for the acts of the co-conspirators, even if they did not personally perform the act of shooting the victims. Extrajudicial confessions, if voluntarily given and corroborated by circumstantial evidence, are admissible and can be the basis for conviction.