People v. Maqueda
REITERATIONFacts
The Antecedents: On August 27, 1991, spouses Horace William Barker and Teresita Mendoza Barker were victims of a robbery in their home in Tuba, Benguet. Horace William Barker was killed, and Teresita Mendoza Barker sustained serious physical injuries. The crime was perpetrated by Rene Salvamante and Hector Maqueda. Procedural History: An information for robbery with homicide and serious physical injuries was initially filed against Rene Salvamante and Richard Malig. Subsequently, the information was amended to implead Hector Maqueda as co-accused, and Richard Malig was dropped due to insufficient evidence. Hector Maqueda applied for bail, volunteering to be a state witness, claiming to be the least guilty. The Petition: Hector Maqueda appealed his conviction by the Regional Trial Court (RTC) of Benguet, which found him guilty beyond reasonable doubt of robbery with homicide and serious physical injuries, sentencing him to reclusion perpetua. The RTC based its conviction on Maqueda's extrajudicial confession, proof of corpus delicti, and circumstantial evidence, despite doubts on the positive identification by prosecution witnesses.
Issue(s)
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime charged based on the Sinumpaang Salaysay. Whether the admissions made by the accused-appellant to Prosecutor Zarate and Ray Dean Salvosa are admissible. Whether the circumstantial evidence presented sufficiently established the guilt of the accused-appellant beyond reasonable doubt. Whether the defense of alibi is tenable. Whether the conviction can be sustained based on admissible evidence and proof of corpus delicti, despite the inadmissibility of the Sinumpaang Salaysay as a confession.
Ruling
The appeal is dismissed, and the decision of the RTC is affirmed in toto. Hector Maqueda is found guilty beyond reasonable doubt of the crime of robbery with homicide and serious physical injuries.
Ratio Decidendi
On the admissibility of the Sinumpaang Salaysay: The Supreme Court ruled that the Sinumpaang Salaysay taken by SPO2 Molleno was inadmissible because it was obtained in violation of Maqueda's constitutional rights under Section 12(1), Article III of the Constitution. Maqueda was not informed of his rights to remain silent and to counsel, and the statement was taken in the absence of counsel. The Court clarified that the rights under Section 12(1) are available at any time before arraignment when a person is under investigation, not just during custodial interrogation. The trial court erred in considering the investigation as outside the ambit of custodial investigation simply because a case had been filed. On the admissibility of admissions to Prosecutor Zarate and Ray Dean Salvosa: The Court held that the admissions made by Maqueda to Prosecutor Zarate and Ray Dean Salvosa are admissible. The admission to Prosecutor Zarate was made in connection with Maqueda's plea to be a state witness and not in the course of a custodial investigation. The admission to Ray Dean Salvosa, a private person, is admissible under Section 26, Rule 130 of the Rules of Court as a declaration of a party against interest. These admissions, along with his motion for bail expressing willingness to be a state witness, established his participation in the crime. On the sufficiency of circumstantial evidence: The Court found that the circumstantial evidence presented sufficiently established Maqueda's guilt beyond reasonable doubt. These circumstances included his presence near the crime scene with a companion an hour after the crime, his friendship with the co-accused Rene Salvamante, their being together in Guinyangan, Quezon, his arrest in Guinyangan, and his offer to be a state witness stating he was the least guilty. The Court reiterated that circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts are proven, and the combination of circumstances produces conviction beyond reasonable doubt, forming an unbroken chain pointing to the accused to the exclusion of others. On the defense of alibi: The Court rejected Maqueda's defense of alibi. His alibi was contradicted by the testimony of Mike Tayaban, who placed him near the crime scene shortly after the incident. Furthermore, his claim of employment at a polvoron factory was disproven by the owner's testimony that the factory only started operations after the crime was committed. The Court emphasized that for alibi to prosper, it must be physically impossible for the accused to have been at the scene of the crime, a requirement not met by Maqueda. On the conviction based on admissible evidence and corpus delicti: While the Court found the Sinumpaang Salaysay inadmissible as a confession, it noted that the trial court also considered it as an admission. However, the Court ultimately affirmed the conviction based on the admissible extrajudicial admissions and the strong circumstantial evidence, which collectively proved Maqueda's guilt beyond reasonable doubt. The Court also noted the proof of corpus delicti, referring to the death of Mr. Barker and the injuries sustained by Mrs. Barker, as well as the stolen items.
Main Doctrine
An extrajudicial confession, to be admissible, must be voluntary and obtained in compliance with constitutional rights, particularly the right to counsel during custodial investigation. Admissions made to private individuals or in non-custodial settings are generally admissible. Conviction may be based on circumstantial evidence if it establishes guilt beyond reasonable doubt.