People v. Surigawan
REITERATIONFacts
The Antecedents: Accused-appellant Odon Surigawan, along with Herminiano Aperdo, Daniel Bahaynon, and Alejandro Uayan, were charged with Robbery with Homicide. The crime occurred on March 4, 1985, in the residence of the victim, Teodoro Donia, in Bukidnon. The victim, a 69-year-old widower, was found dead the following morning with multiple wounds, and P3,000.00 was missing from his house. The crime was committed inside the victim's dwelling. Procedural History: Upon arraignment, all four accused pleaded not guilty. During the trial, Aperdo, Bahaynon, and Uayan changed their plea to guilty and were sentenced accordingly. Accused-appellant Surigawan maintained his innocence. The trial court convicted Surigawan based on his extra-judicial statement admitting guilt and the extra-judicial statements of his co-accused implicating him. The trial court appreciated the aggravating circumstances of superior strength and dwelling. The Petition: Accused-appellant Surigawan appealed the decision, assailing the admission and reliance on the extra-judicial confessions of the accused, including his own, in his conviction.
Issue(s)
Whether the trial court erred in admitting in evidence the extra-judicial confessions of the accused and relying on them in convicting the accused-appellant. Whether the trial court erred in admitting and relying on the co-accused's extra-judicial confessions to convict the accused-appellant. Whether the trial court erred in not finding for the accused-appellant and acquitting him of the charge due to insufficient evidence.
Ruling
The Supreme Court reversed and set aside the decision of the Regional Trial Court, acquitting the accused-appellant Odon Surigawan from the charge of Robbery with Homicide. The Court found that the guilt of the accused-appellant was not established by competent and credible evidence.
Ratio Decidendi
On the admissibility and reliance on extra-judicial confessions: The Supreme Court held that the trial court committed a grave error in admitting and relying on the extra-judicial statement of accused-appellant Surigawan (Exh. "H"), as it was obtained without the assistance of counsel. The Court emphasized that any confession or admission obtained in violation of the constitutional rights of an accused, specifically the right to remain silent and to have competent and independent counsel, is inadmissible in evidence. This is in accordance with Section 12 (1) and (3) of Article III of the Constitution. The Court reiterated the well-settled ruling that uncounselled confessions cannot be used to convict. On the admissibility of co-accused's confessions: The Court further found that the trial court erred in using the extra-judicial confessions of the other accused (Exhibits "B", "F", and "J") to convict accused-appellant Surigawan. The Court clarified that for the act or declaration of a conspirator to be admissible against a co-conspirator under Section 30 of Rule 130, several requisites must be satisfied: (a) the conspiracy must be proved by evidence other than the admission itself; (b) the admission must relate to the common objects of the conspiracy; and (c) it must have been made while the declarant was engaged in carrying out the conspiracy. In this case, the alleged conspiracy was not independently established, and the confessions were made after the crime was consummated, not during its commission. Therefore, these confessions could not be used against Surigawan without violating his constitutional right to be confronted with the witnesses against him and to cross-examine them. On the sufficiency of evidence for conviction: Without the uncounselled confession of the accused-appellant and the extra-judicial confessions of the other accused, the Supreme Court found that no shred of evidence remained to establish the guilt of accused-appellant Surigawan beyond reasonable doubt. The prosecution did not present any witness who identified Surigawan as one of the perpetrators. The daughter of the victim could only state that she saw two persons under the house but failed to recognize them. Consequently, the Court concluded that the conviction was not supported by competent and credible evidence.
Main Doctrine
An extra-judicial confession obtained in violation of the constitutional rights of an accused, specifically the right to remain silent and to have competent and independent counsel, is inadmissible in evidence. Furthermore, the act or declaration of a conspirator relating to the conspiracy and during its existence may be given in evidence against co-conspirators only after the conspiracy is shown by evidence other than such act or declaration, and the admission relates to the common objects and was made while the declarant was engaged in carrying out the conspiracy.