People v. Garde
REITERATIONFacts
The Antecedents: The accused-appellant, Dimson M. Garde, along with Edeme C. Tayapad, was charged with murder for the killing of Noli Diaz. The information alleged that on May 14, 1987, in Bacolod City, the accused, armed with bladed weapons, conspired, confederated, and acted in concert with intent to kill, by means of treachery and evident premeditation, and taking advantage of superior strength, assaulted and stabbed Noli Diaz, causing multiple wounds that directly resulted in his death. Procedural History: The Regional Trial Court (RTC) found both accused guilty beyond reasonable doubt of murder and sentenced them to reclusion perpetua, ordering them to indemnify the heirs of the victim. The accused-appellant initially withdrew his appeal, but later reinstated it. Edeme C. Tayapad was reported to be at large. The Petition: The accused-appellant appealed the RTC decision, asserting that the trial court erred in finding him guilty beyond reasonable doubt of murder and in admitting his extra-judicial confession.
Issue(s)
Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of the crime of murder. Whether the trial court erred in admitting the accused-appellant's extra-judicial confession.
Ruling
The Supreme Court affirmed the decision of the trial court with a modification increasing the civil indemnity. The Court found the accused-appellant guilty beyond reasonable doubt of murder and sentenced him to reclusion perpetua. The civil indemnity for the victim's death was increased from P30,000.00 to P50,000.00.
Ratio Decidendi
On the issue of guilt beyond reasonable doubt: The Court found the evidence of the prosecution sufficient to warrant conviction. The eyewitness account of Jonathan Balabag was deemed clear, credible, and substantially corroborated by the physical evidence and medical findings. Balabag testified that Tayapad stabbed Diaz first from behind after tapping his shoulder, and then the appellant Garde emerged and also stabbed Diaz. Both assailants continued to stab the victim even after he fell. The prosecution presented evidence of eleven (11) wounds sustained by the victim, which caused his death. The Court gave credence to the eyewitness testimony, noting that even uncorroborated testimony, if plausible, is sufficient for conviction. The Court also found no ulterior motive for the witness to testify falsely against the appellant. The trial court's assessment of the witness's credibility was respected, as the judge had the advantage of observing the witness's demeanor. On the admissibility of the extrajudicial confession: The Court found no reversible error in the admission of the extrajudicial confession. The Court noted that even without the confession, the prosecution's evidence was sufficient for conviction. Furthermore, the appellant's own testimony appeared to belie his claim of coercion. The confession was executed with the assistance of counsel and subscribed and sworn to before an Assistant City Fiscal. The Court also pointed out that the appellant did not file any complaint with the proper authorities regarding the alleged maltreatment. The trial court observed that the contents of the confession practically jibed with the appellant's testimony in court and corroborated the testimony of the prosecution witness Jonathan Balabag.
Main Doctrine
The Court affirmed the conviction for murder, holding that the prosecution's evidence, including eyewitness testimony and physical evidence, was sufficient to establish guilt beyond reasonable doubt, and that the extrajudicial confession, though challenged, was corroborated by other evidence and executed with the assistance of counsel.