People v. Lorenzo
REITERATIONFacts
The Antecedents: On July 30, 1990, Agapito Lorenzo was allegedly killed by his wife, Dolores Lorenzo, a policewoman. The information charged Dolores Lorenzo with parricide, alleging that she attacked her husband with a bolo and a fan knife with intent to kill, evident premeditation, and treachery, and that cruelty was an aggravating circumstance. Procedural History: The Regional Trial Court (RTC), Branch 5, Tuguegarao, Cagayan, found the appellant guilty of parricide and sentenced her to suffer the penalty of reclusion perpetua and to pay P50,000.00 to the heirs of the victim. The RTC rejected the defense's theory that Robert Santos killed Agapito Lorenzo, finding the appellant's story "palpably a put-up scenario." The RTC considered the appellant's surrender of the weapons and her statement to SPO1 Jose Eclipse that she killed her husband as an admissible extrajudicial confession. The Petition: The appellant appealed to the Supreme Court, arguing that the RTC erred in giving credence to the testimonies of prosecution witnesses Isabelo Liban and SPO1 Jose Eclipse and in not holding that her guilt was not proved beyond reasonable doubt. She contended that the testimonies of Liban and Eclipse were inconsistent and that her alleged confession lacked corroboration.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of prosecution witnesses Isabelo Liban and SPO1 Jose Eclipse. Whether the guilt of the accused was proved beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the appellant guilty of parricide. The Court held that the appellant's admission of killing her husband, though an admission and not a confession, was admissible and, when corroborated by circumstantial evidence, was sufficient for conviction. The Court also found no merit in the appellant's claims regarding inconsistencies in witness testimonies and suppression of evidence. The penalty imposed was reclusion perpetua, with the mitigating circumstance of voluntary surrender considered.
Ratio Decidendi
On the credibility of prosecution witnesses: The Supreme Court reiterated that appellate courts generally do not disturb the trial court's credibility findings. The Court found no plain error. SPO1 Jose Eclipse's testimony was credible, with no improper motive to implicate a fellow officer. The inconsistency regarding "injured" or "killed" was minor. Testimony of the person to whom the confession was made does not require corroboration, and a single credible witness can suffice. The corpus delicti was overwhelmingly established. There was no suppression of evidence, as the other policeman's testimony was corroborative and available to the defense. Minor inconsistencies strengthen credibility. On proof of guilt beyond reasonable doubt: The appellant's defense was implausible, particularly her failure to immediately identify Robert Santos and file a case against him. Her admission was admissible, shifting the burden to disprove her guilt. Circumstantial evidence, including surrender of weapons, presence at the scene, failure to protest SPO1 Eclipse's report, and delayed implication of Robert Santos, established guilt beyond reasonable doubt. The mitigating circumstance of voluntary surrender was considered in imposing the penalty.
Main Doctrine
An extrajudicial confession, to be sufficient for conviction, must be corroborated by evidence of corpus delicti. However, an admission, while not sufficient on its own, can be admitted as evidence and, when combined with other facts and circumstances, can lead to conviction.