People v. Bacor
REITERATIONFacts
The Antecedents: On March 17, 1991, at around 9:00 PM, Dionisio Albores was shot inside his dwelling in Barangay Señor, Sinacaban, Misamis Occidental. Julian Albores, the victim's father, heard the gunshot and found his son lying on the kitchen floor with blood oozing from his right armpit. Dionisio Albores was brought to the hospital but died shortly thereafter. A post-mortem examination revealed that the cause of death was internal hemorrhage secondary to multiple gunshot wounds. Procedural History: On June 6, 1991, accused-appellant Victor Bacor voluntarily surrendered to the police, confessing to the killing due to a guilty conscience. He was assisted by a Public Attorney's Office (PAO) lawyer during the custodial investigation where he executed a written extrajudicial confession. The Regional Trial Court (RTC) found Victor Bacor guilty of murder and sentenced him to an indeterminate penalty. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua. The case was elevated to the Supreme Court for review. The Petition: Accused-appellant assailed the admissibility of his extrajudicial confession, arguing that it was obtained in violation of his constitutional rights. He also questioned the weight given to the evidence against him and the finding of guilt.
Issue(s)
Whether the extrajudicial confession of accused-appellant Victor Bacor is admissible in evidence. Whether the guilt of accused-appellant Victor Bacor for the crime of murder has been proved beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the Court of Appeals, upholding the conviction of accused-appellant Victor Bacor for murder and sentencing him to reclusion perpetua. The Court found that the extrajudicial confession was admissible in evidence and was corroborated by evidence of the corpus delicti.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the extrajudicial confession of accused-appellant Victor Bacor was admissible in evidence. The records showed that he voluntarily surrendered and confessed due to a guilty conscience. Crucially, he was informed of his constitutional rights to remain silent and to have counsel not just once, but thrice: by his PAO lawyer, the police investigator, and the branch clerk of court. He expressly accepted the assistance of the PAO lawyer, who was deemed competent and independent. The confession was in writing, signed by the accused-appellant in the presence of his counsel, and sworn to before the branch clerk of court. The Court reiterated that for a confession to be admissible, it must be voluntary, made with the assistance of competent and independent counsel, express, and in writing. The circumstances surrounding the confession, including the presence of counsel and the repeated advisement of rights, demonstrated an effective waiver of his right to remain silent. The Court emphasized that a PAO lawyer qualifies as an independent counsel under the Constitution. On the guilt of accused-appellant Victor Bacor: The Court found that the guilt of accused-appellant was proven beyond reasonable doubt. The admissible extrajudicial confession, which was replete with details only the perpetrator could know, was corroborated by evidence of the corpus delicti. The death certificate and medical certificate, affirmed by the examining physician, established the fact of death and the criminal agency. The details of the gunshot wounds and the cause of death conformed with the confession. The Court also dismissed the defense of alibi, noting that it was inherently weak and easily fabricated, especially when established by the accused or his relatives. Furthermore, the claimed alibi was not physically impossible, as the distance between his claimed location and the crime scene was only one kilometer and easily accessible by transportation. The Court also noted that retractions of confessions are generally viewed with disfavor and considered unreliable.
Main Doctrine
An extrajudicial confession, if corroborated by evidence of the corpus delicti and obtained with the assistance of competent and independent counsel after informing the accused of his constitutional rights, is sufficient to support a conviction. The waiver of the right to remain silent need not be in a separate written document if the confession itself is in writing, signed in the presence of counsel, and sworn to before a notary or clerk of court.