People v. Campos
REITERATIONFacts
The Antecedents: On the evening of May 25, 1986, members of the Hilardes family, namely Rosendo, Conchita, Santos, and Pablo, were attacked with bladed weapons by a group of persons. Rosendo, Conchita, and Santos Hilardes died from their injuries, while Pablo Hilardes survived despite serious wounds. An information for multiple murder and frustrated murder was filed against Jose Napigkit, Severino Campos, Pablito Baynosa, and several others who were at large. Only Jose Napigkit, Pablito Baynosa, and Severino Campos were arrested and tried. Procedural History: The Regional Trial Court (RTC) found Severino Campos guilty beyond reasonable doubt of multiple murder and frustrated murder, considering the aggravating circumstances of dwelling, band, and cruelty, with voluntary surrender as a mitigating circumstance. The RTC sentenced Campos to three counts of Reclusion Perpetua for the deaths and an indeterminate penalty for the frustrated murder, ordering him to indemnify the heirs of the victims. Jose Napigkit and Pablito Baynosa were acquitted for lack of evidence. The case was elevated to the Court of Appeals but was erroneously forwarded to the Supreme Court due to the penalty imposed. The Petition: Severino Campos appealed his conviction, assigning as errors the trial court's credence to the testimony of Macario Hilardes and its failure to acquit him.
Issue(s)
Whether the extra-judicial confession of the accused-appellant is admissible in evidence. Whether the testimony of the lone eyewitness, Macario Hilardes, is credible and sufficient to establish the guilt of the accused-appellant beyond reasonable doubt. Whether conspiracy was sufficiently proven.
Ruling
The Supreme Court REVERSED the decision of the Regional Trial Court and ACQUITTED the accused-appellant Severino Campos y de la Torre on the ground of reasonable doubt. The Court found the extra-judicial confession inadmissible and the testimony of the lone eyewitness insufficient to establish guilt beyond reasonable doubt.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Supreme Court ruled that the extra-judicial confession of Severino Campos was inadmissible in evidence. The Court found that the confession was not voluntarily given, as Campos testified that he was promised release if he signed the document and was threatened with rotting in jail if he refused. Furthermore, the confession was obtained in violation of Campos's constitutional right to counsel during custodial investigation. Although a lawyer was present, he was not of Campos's choice, did not assist him throughout the entire investigation, and the confession was completed by the police before the lawyer could fully participate. The Court emphasized that confessions obtained on promises of release or without competent and independent counsel are inadmissible. On the credibility and sufficiency of the testimony of Macario Hilardes: The Supreme Court found the testimony of Macario Hilardes, the lone eyewitness, to be insufficient to establish the guilt of Severino Campos beyond reasonable doubt. The Court noted that Macario did not witness the actual killing of the victims and only identified Campos as part of the armed group. Crucially, Macario did not identify Campos in his sworn statement executed shortly after the incident, but only did so during his testimony in court six months later. The Court found this delay and inconsistency unusual and suspect, going against the natural course of human behavior, especially given Macario's close relationship with the victims. The Court also highlighted inconsistencies in Macario's narration of events and questioned why Macario, a potential eyewitness, was spared by the assailants. On the existence of conspiracy: The Supreme Court held that conspiracy was not sufficiently proven. The Court reiterated that mere presence at the scene of the crime does not imply conspiracy. It found no overt act on the part of Campos that could be construed as an act in furtherance of a conspiracy. The Court noted that the trial court's finding of conspiracy was based on inferences and conjectures rather than positive and convincing evidence. The Court also pointed out the inconsistency in acquitting Pablito Baynosa while convicting Campos, when the prosecution's evidence against both was essentially the same and deemed insufficient.
Main Doctrine
An extra-judicial confession is inadmissible in evidence if obtained in violation of the constitutional rights of the accused, specifically the right to counsel during custodial investigation, or if it was not voluntarily given.