People v. Javar y Pablo
REITERATIONFacts
The Antecedents: On May 20, 1984, in Manila, Teodoro Garcia confronted Reynaldo Balberan regarding a past grievance. An argument ensued, after which Garcia spoke with Eugenio Javar y Pablo. Javar then approached Balberan, Rodolfo Arpon, and Danilo Garcia, inquired about their enemy, and upon learning it was Teody, drew a knife. Javar initially aimed at Arpon and Garcia, who fled, and then turned to Balberan, grabbed him by the shoulder, and stabbed him below the navel. Balberan was rushed to the hospital but died upon arrival due to a stab wound that caused shock secondary to a severed artery and perforation of internal organs. Procedural History: The Regional Trial Court of Manila, Branch 32, found Eugenio Javar y Pablo guilty of murder and sentenced him to life imprisonment, with indemnity to the heirs of the deceased and costs. The accused was to be credited with the full time of his preventive imprisonment. The Petition: Eugenio Javar y Pablo appealed the decision, assigning errors concerning the trial court's reliance on prosecution witnesses, the admissibility of his extrajudicial confession, the sufficiency of evidence for murder, and the absence of treachery.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses. Whether the trial court erred in giving probative value to the extrajudicial confession of the accused despite alleged violation of his constitutional rights. Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the crime of murder. Whether the trial court erred in convicting the accused of murder instead of homicide, absent proof of treachery.
Ruling
The Supreme Court affirmed the conviction of Eugenio Javar y Pablo for murder but modified the penalty to reclusion perpetua and increased the death indemnity to P50,000.00. The Court ruled that while the extrajudicial confession was inadmissible due to violation of the right to counsel, the accused's guilt was established beyond reasonable doubt by the credible eye-witness testimony of Rodolfo Arpon. The Court also found that treachery was present, and the accused's flight constituted a tacit admission of guilt.
Ratio Decidendi
On the credibility of prosecution witnesses: The Court held that ill-feeling allegedly harbored by a prosecution witness against the accused does not automatically render his testimony perjurious, as improper motives are not presumed. The appellate court generally defers to the trial court's findings on credibility, as the trial court had the opportunity to observe the witnesses' demeanor and manner of testifying. The description of the accused as a braggart did not prove an improper motive or an axe to grind. On the admissibility of the extrajudicial confession: The Court found the extrajudicial confession inadmissible because it was obtained in violation of the accused's constitutional right to counsel. The records did not indicate that the accused was assisted by counsel when he waived this right, rendering the confession inadmissible even if voluntarily given and truthful. This omission is fatal to its admissibility under Article III, Section 12 of the 1987 Constitution. On the proof of guilt beyond reasonable doubt for murder: Despite the inadmissibility of the confession, the Court found that the accused's guilt was established beyond reasonable doubt by the independent, credible eye-witness testimony of Rodolfo Arpon, who positively identified the accused as the killer. The Court reiterated the principle that where independent evidence exists apart from an uncounselled confession, conviction can still be had. Motive, in this case, was rendered immaterial by the positive identification of the assailant. On the presence of treachery: The Court affirmed the trial court's finding of treachery. The accused employed means to insure the execution of the crime without risk to himself by pretending to aim at other individuals, thereby lulling the victim into a false sense of security. The victim was unarmed, attacked without warning, and in a defenseless position, with the accused immobilizing and incapacitating him, thus preventing any defense. Even a frontal attack can be treacherous if it is sudden, unexpected, and the victim is unarmed.
Main Doctrine
An extrajudicial confession obtained in violation of the right to counsel is inadmissible in evidence, but guilt can still be established by independent evidence, such as credible eye-witness testimony. Flight is a tacit admission of guilt.