People v. Cayago
REITERATIONFacts
The Antecedents: Rolando Cayago y Reyes was indicted for parricide for the killing of his wife, Myra Cayago, through strangulation with evident premeditation. The appellant reported finding his wife's decomposing body at an abandoned barangay hall. During initial police questioning, Cayago provided inconsistent statements. Subsequently, while being accompanied to Camp Crame for a polygraph test, Cayago requested to go to a nearby church, where he admitted to SPO2 Delos Reyes that he killed his wife and was willing to give a statement. He was then assisted by Atty. Reynario Campanilla, who advised him of his constitutional rights before Cayago wrote down his confession. This extrajudicial confession was later tape-recorded in the presence of Atty. Campanilla and SPO2 Delos Reyes. Procedural History: The Regional Trial Court (RTC) found the appellant guilty of parricide and sentenced him to death, ordering him to pay damages to the victim's heirs. The RTC's decision summarized witness testimonies and concluded guilt in a single paragraph, finding the defense's version not credible and noting the appellant's admission that he killed his wife and misled the police by reporting her as missing. The Petition: The appellant appealed his conviction and sentence to the Supreme Court.
Issue(s)
Whether the appellant's extrajudicial confession is admissible in evidence. Whether the appellant is guilty of parricide. Whether the aggravating circumstances of nighttime and uninhabited place were present. Whether the death penalty was correctly imposed, and the matter of civil liability.
Ruling
The Supreme Court affirmed the conviction for parricide but modified the penalty imposed by the trial court. The death penalty was reduced to reclusion perpetua. The award of P50,000.00 as civil indemnity and P26,000.00 as actual damages was affirmed, while the award of moral damages was deleted for lack of evidence.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the appellant's extrajudicial confession was admissible. The right to counsel under Section 12(1), Article III of the 1987 Constitution applies only to persons under investigation. The appellant was not under custodial investigation when he initially reported the incident and volunteered information. He reported the incident himself and later admitted to killing his wife before being formally investigated. Furthermore, he was assisted by counsel, Atty. Campanilla, during the formal taking of his confession, who advised him of his constitutional rights. The presence and assistance of counsel during the confession rendered it valid. On the guilt of the appellant for parricide: The Court found sufficient evidence to establish the appellant's guilt for parricide. The elements of parricide were met: a person was killed, the deceased was killed by the accused, and the deceased was the legitimate spouse of the accused. The appellant's extrajudicial confession, corroborated by his testimony in court and the medical findings of asphyxia by strangulation, clearly established his culpability. The medical findings of a fractured windpipe and hemorrhage inside the windpipe contradicted the appellant's claim of merely embracing his wife tightly, indicating manual strangulation. On the aggravating circumstances of nighttime and uninhabited place: The Court ruled that the aggravating circumstances of nighttime and uninhabited place were not sufficiently proven. While the crime occurred at midnight in an abandoned barangay hall, there was no evidence that the appellant specifically took advantage of the darkness or the isolation of the place to facilitate the commission of the crime. The Court emphasized that aggravating circumstances must be proven beyond reasonable doubt, and any doubt must be resolved in favor of the accused. The appellant's act of reporting his wife missing the next day was seen as an attempt to divert suspicion, not as proof of taking advantage of the circumstances. On the imposition of the death penalty and civil liability: The Court found that the trial court erred in imposing the death penalty. The death penalty can only be imposed if there is an aggravating circumstance that concurs with the commission of the crime. Since the aggravating circumstances of nighttime and uninhabited place were not proven, and no other aggravating circumstance was established, the lower penalty of reclusion perpetua should have been imposed. The Court cited Article 63 of the Revised Penal Code, which mandates the imposition of the lower penalty when there are two indivisible penalties and no mitigating or aggravating circumstances. The Court affirmed the award of civil indemnity and actual damages, consistent with Article 100 of the Revised Penal Code. However, the award of moral damages was deleted for lack of evidence, as there was nothing in the records to support the claim for such damages.
Main Doctrine
The Court affirmed the conviction for parricide but modified the penalty from death to reclusion perpetua due to the absence of proven aggravating circumstances. The Court also clarified the application of the right to counsel and the requirements for imposing the death penalty.