People v. Alvarez
REITERATIONFacts
The Antecedents: The accused-appellants, Henry Alvarez y San Juan, Antonio Barcenas y Bastida, and Renato Abasola y Collantes, along with an unknown accused, were charged with Rape With Homicide. The information alleged that on or about October 31, 1990, in Sta. Cruz, Laguna, the accused, conspiring and confederating, with the use of force and violence, unlawfully and feloniously had carnal knowledge of Cristina G. Carillo against her will. On the occasion of the felony, and to conceal the crime, they attacked and stabbed the victim with bladed instruments, causing her death. Aggravating circumstances of nighttime and superior strength were alleged. Procedural History: The Regional Trial Court, Branch 28, Sta. Cruz, Laguna, found the three accused, Alvarez, Barcenas, and Abasola, guilty beyond reasonable doubt of Rape With Homicide. Each was sentenced to life imprisonment and ordered to pay civil indemnity to the heirs of the deceased. The Petition: The accused-appellants appealed the decision, raising issues concerning the admissibility of Henry Alvarez's extrajudicial confession, the sufficiency of circumstantial evidence, and the failure of the prosecution to overcome the presumption of innocence.
Issue(s)
Whether the extrajudicial confession of Henry Alvarez is admissible in evidence. Whether the circumstantial evidence presented by the prosecution, including Alvarez's confession, is sufficient to establish the guilt of the accused-appellants beyond reasonable doubt. Whether the alibis of the accused-appellants are sufficient to exculpate them.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court with modifications. The three accused-appellants, Henry Alvarez, Antonio Barcenas, and Renato Abasola, were sentenced to suffer the penalty of reclusion perpetua. The indemnity for the death of Cristina G. Carillo was increased to P50,000.00. All other damage awards were affirmed.
Ratio Decidendi
On the admissibility of the extrajudicial confession of Henry Alvarez: The Court held that the extrajudicial confession of Henry Alvarez was admissible. The testimonies of Pfc. Percival Gabinete, Pfc. Reynaldo Martinez, and Atty. Dionides A. Perez established that Alvarez was assisted by counsel, Atty. Perez, when he executed the confession. Atty. Perez himself testified that he informed Alvarez of his right to remain silent and that he was not maltreated or promised any reward. The Court reiterated the settled rule that an extrajudicial confession made by an accused who is duly assisted by counsel is admissible unless the accused successfully proves it was obtained through violence, intimidation, threat, or promise of reward or leniency. Alvarez's self-serving claims of threats and lack of counsel were belied by the testimonies of the peace officers and the lawyer. On the sufficiency of circumstantial evidence and the use of the confession against co-accused: The Court ruled that the extrajudicial confession of Alvarez, while generally binding only on the confessant, could be used as circumstantial evidence to show the probability of participation of his co-accused. The trial court convicted the appellants based on circumstantial evidence found sufficient to overcome the presumption of innocence. The prosecution established several circumstances: (1) the presence of the accused-appellants at the vicinity of the crime scene around 8:00 p.m. and again at midnight on October 31, 1990, following the victim; (2) the proximity of the location where they were seen to where the victim's body was found; (3) the victim's arrival in Sta. Cruz, Laguna, around midnight on the same date, as evidenced by a bus ticket found on her person; (4) the discovery of the victim's naked and mutilated body with injuries indicating sexual assault; (5) the estimated time of death coinciding with the date of the offense; (6) the suspicious conduct of Alvarez, who went into hiding; and (7) Alvarez's extrajudicial statement admitting his presence with the other accused during the rape, though he attempted to exculpate himself regarding the killing. On the alibis of the accused-appellants: The Court found the alibis of the accused-appellants unconvincing and insufficient to overcome the evidence presented by the prosecution. Henry Alvarez claimed to be at his mother's house but failed to corroborate this alibi, and it was not impossible for him to be at the scene. Antonio Barcenas claimed to be at home, but his wife did not corroborate his alibi, and his house was only half a kilometer from the crime scene. Renato Abasola claimed to be at a dance party, but the travel time from that location to the scene of the crime was less than an hour. The Court emphasized that alibi is a weak defense, especially when uncorroborated and when the accused's presence at the scene of the crime is not impossible.
Main Doctrine
An extrajudicial confession made by an accused who is duly assisted by counsel is admissible in evidence, provided it is not proven to have been obtained through violence, intimidation, threat, or promise of reward or leniency. Furthermore, when circumstantial evidence is sufficient to establish guilt beyond reasonable doubt, it can be used to convict accused-appellants, even if the primary evidence is an extrajudicial confession of a co-accused.