People v. Gallardo
REITERATIONFacts
The Antecedents: On July 28, 1991, the lifeless body of Edmundo Orizal was found with seven gunshot wounds. Investigation identified Armando Gallardo y Gander, Alfredo Columna y Correa, and Jessie Micate y Orteza as suspects. Gallardo and Columna, detained for other charges, were investigated by SPO4 Isidro Marcos. Atty. Rolando Velasco assisted them, and Judge Vilma Pauig administered the oath on their sworn statements, wherein they admitted to killing Edmundo Orizal. According to their statements, they were hired by Congressman Domingo Tuzon, through Pat. Dennis Molina, to kill Orizal, who was allegedly planning to ambush the congressman and grab his land. They were provided with firearms and executed the killing on July 27, 1991, at Ronnie Balao's rest house. They then reported to Pat. Molina and later to Congressman Tuzon, who promised them acquittal and cash rewards. Procedural History: The Provincial Prosecutor filed an information for murder against the three accused. They pleaded not guilty. The trial court found Armando Gallardo y Gander and Alfredo Columna y Correa guilty of murder, sentencing them to reclusion perpetua and ordering them to pay in solidum P50,000.00 as indemnity and P150,000.00 as moral damages. Jessie Micate y Ortega was acquitted for lack of evidence. The accused-appellants appealed. The Petition: Accused-appellants Armando Gallardo y Gander and Alfredo Columna y Correa appealed, imputing errors to the trial court in admitting their extra-judicial confessions and in finding their guilt proved beyond reasonable doubt.
Issue(s)
Whether the extra-judicial confessions of the accused-appellants were admissible in evidence. Whether the guilt of the accused-appellants was proved beyond reasonable doubt.
Ruling
The Supreme Court affirmed the decision of the trial court finding accused-appellants Armando Gallardo y Gander and Alfredo Columna y Correa guilty beyond reasonable doubt of murder. The Court also affirmed the sentence of reclusion perpetua and the award of P50,000.00 as mandatory indemnity for death. However, the award of moral damages was reduced to P50,000.00. The Court referred the case to the Department of Justice for investigation into the involvement of former Congressman Tuzon and Pat. Molina.
Ratio Decidendi
On the admissibility of extra-judicial confessions: The Court held that the extra-judicial confessions of the accused-appellants were admissible. The confessions were given after they were completely and clearly apprised of their Constitutional rights. Atty. Rolando Velasco assisted them, and Judge Vilma Pauig administered their oath. Atty. Velasco testified that he interrogated the accused, informed them of their right to remain silent and to have counsel, and that their statements could be used against them. He confirmed that the accused accepted his assistance and that he ensured no force or intimidation was used by the police. Judge Pauig also testified that she asked the accused if they understood their statements and if they were forced, to which they answered in the negative. 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. All these requirements were met in this case. The Court emphasized that the presence of counsel is to preclude coercion, not to prevent the accused from telling the truth. On the proof of guilt beyond reasonable doubt: The Court found no merit in the contention that the prosecution failed to establish the guilt of the accused beyond reasonable doubt. The testimony of prosecution witness Nelson Hidalgo remained uncontroverted, and the defense did not present evidence to prove his bias or lack of credibility. The Court reiterated its policy not to interfere with the trial court's assessment of witness credibility absent any indication of overlooked material facts or grave abuse of discretion. Therefore, the trial court correctly found the accused-appellants guilty beyond reasonable doubt of the treacherous murder of Edmundo Orizal.
Main Doctrine
Extra-judicial confessions are admissible if voluntarily given, with the assistance of competent and independent counsel, in writing, and express. The presence of counsel during custodial investigation is to prevent coercion, not to prevent the accused from telling the truth.