People v. Molas
REITERATIONFacts
The Antecedents: Appellant Josue Molas was convicted of three counts of murder for the killings of Dulcesima Resonable, her mother Soledad Resonable, and Dulcesima's eight-year-old brother, Abelardo Resonable. The crimes occurred on February 2, 1983, in Valencia, Negros Oriental. The prosecution presented evidence that Molas, the fiancé of Dulcesima, attacked and fatally wounded all three victims with a bladed weapon. The victims sustained multiple stab and incised wounds, leading to their deaths. Molas surrendered to the authorities the following morning, still in possession of blood-stained clothing and the alleged murder weapon. Procedural History: Following the incident, three separate Informations for murder were filed against Josue Molas before the Regional Trial Court, Branch 44, of Dumaguete City. The cases were jointly tried due to their common origin and parties. Molas pleaded not guilty to all charges. The trial court, after considering the evidence presented by both the prosecution and the defense, including Molas's extrajudicial confession and the dying declaration of Abelardo Resonable, found Molas guilty beyond reasonable doubt of three counts of murder. He was sentenced to reclusion perpetua in each case and ordered to pay civil indemnity to the heirs of the victims. Molas appealed this decision to the Supreme Court. The Petition: In his appeal to the Supreme Court, Josue Molas argued that the trial court erred in admitting his extra-judicial confession, asserting it was obtained without the assistance of counsel as mandated by the Constitution. He also challenged the trial court's reliance on the dying declaration of Abelardo Resonable and contended that his guilt was not proven beyond a reasonable doubt. The Supreme Court, however, affirmed the trial court's decision, finding that while the confession might be inadmissible in its original form, it could be treated as a verbal admission. The Court also upheld the admissibility and weight of Abelardo's dying declaration and found sufficient corroborating evidence, including Molas's surrender with the weapon and blood-stained clothes, and his admissions to police officers, to establish his guilt beyond reasonable doubt.
Issue(s)
Whether the extra-judicial confession of the accused-appellant, executed without the assistance of counsel, is admissible as evidence. Whether the dying declaration of Abelardo Resonable was admissible and correctly given weight by the trial court. Whether the guilt of the accused-appellant was proven beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding Josue Molas guilty beyond reasonable doubt of the murders of Dulcesima Resonable, Soledad Resonable, and Abelardo Resonable. The Court sentenced him to suffer the penalty of reclusion perpetua for each murder and increased the death indemnity to P50,000.00 for each case.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Court ruled that while the appellant's extrajudicial confession, as reduced to writing, was made without the advice and assistance of counsel and thus inadmissible as evidence in its written form, it could be treated as a verbal admission of the accused established through the testimonies of the persons who heard it or conducted the investigation. Patrolman Paquito Fetalvero testified to the admissions made by the accused, and the trial court found his testimony credible. The Court cited People vs. Carido, People vs. Feliciano, and People vs. Fontanosa in support of this principle. The Court emphasized that the trial judge observed the deportment of the witness on the stand, which is crucial for assessing credibility. On the admissibility and weight of the dying declaration: The Court held that Abelardo's statement to his father, identifying Josue Molas as the perpetrator, was indubitably a dying declaration. The declaration concerned the cause and surrounding circumstances of Abelardo's death, made under the consciousness of impending death, as he lay bleeding from fatal wounds and expired a few hours later. He was also a competent witness. The Court cited Section 31, Rule 130 of the Rules of Court and People vs. Saliling in affirming the requisites for a dying declaration, all of which were present in this case. On whether guilt was proven beyond reasonable doubt: The Court found that even if the written extrajudicial confession were disregarded, there was more than enough evidence to support the conviction. This evidence included Molas' act of surrendering to the police with the murder weapon and blood-stained clothing shortly after the killings, Abelardo's dying declaration, and the testimonies of policemen to whom Molas admitted his guilt. These pieces of evidence formed an unbroken chain proving beyond reasonable doubt that Molas murdered the three victims. The Court also noted that while treachery was not appreciated, the qualifying circumstance of abuse of superior strength was present, considering Molas' youth, strength, and possession of a weapon against the unarmed and weaker victims, including an eight-year-old boy.
Main Doctrine
The Court affirmed the conviction for murder, holding that while an extrajudicial confession made without counsel is inadmissible, verbal admissions to police officers can be admitted. The Court also upheld the admissibility of a dying declaration and found sufficient evidence, including the dying declaration, the confession (treated as verbal admission), and the surrender with the murder weapon, to prove guilt beyond reasonable doubt. Abuse of superior strength was appreciated as a qualifying circumstance.