People v. Samolde
REITERATIONFacts
The Antecedents: Accused-appellant Ramil Samolde and Armando Andres were charged with murder for the killing of P/Cpl. Feliciano Nepomuceno. The information alleged that the accused, conspiring and confederating, with intent to kill, treachery, and evident premeditation, took the victim's service firearm and shot him, causing his death. Procedural History: The Regional Trial Court (RTC) found both accused guilty of murder and sentenced them to suffer the penalty of reclusion perpetua, with civil indemnity. Only Ramil Samolde appealed the decision. The Petition: Accused-appellant Ramil Samolde contended that the RTC erred in finding complicity by circumstantial evidence and that he was paid by Armando Andres to confess to the murder.
Issue(s)
Whether the testimony of Ricardo Nepomuceno is credible and sufficient to sustain the conviction of accused-appellant. Whether the extrajudicial confession of accused-appellant is admissible in evidence. Whether accused-appellant's judicial confession is sufficient to sustain his conviction. Whether the killing was attended by treachery. Whether the killing was attended by evident premeditation. Whether the heirs of the victim are entitled to actual damages.
Ruling
The Supreme Court affirmed the RTC decision with modifications. It ruled that while the testimony of Ricardo Nepomuceno was not credible and the extrajudicial confession was inadmissible, the judicial confession of Ramil Samolde, coupled with motive and flight, was sufficient to sustain his conviction for murder. The Court also found that treachery was not present, but evident premeditation was established. The award for civil indemnity was affirmed, and actual damages for funeral and burial expenses were awarded.
Ratio Decidendi
On the credibility of Ricardo Nepomuceno's testimony: The Court found Ricardo Nepomuceno's testimony to be not credible due to his unexplained delay in reporting the incident for over a year, casting doubt on its veracity. His narration of events was also contradicted by the medico-legal findings, which showed no stab wounds despite his claim that Armando Andres stabbed the victim. On the admissibility of the extrajudicial confession: The Court ruled that the extrajudicial confession of accused-appellant was inadmissible because he was not properly apprised of his constitutional rights during custodial investigation. The warnings given were merely perfunctory and did not constitute meaningful compliance with the constitutional requirements, rendering the confession invalid. On the sufficiency of the judicial confession: The Court held that accused-appellant's confession in open court was sufficient to sustain his conviction. A judicial confession is considered evidence of high order, and the presumption is that no sane person would confess to a crime unless prompted by truth and conscience. The Court found it hard to believe that a person would confess to a crime he did not commit for a mere monetary consideration. On the presence of treachery: The Court disagreed with the trial court's finding of treachery. It stated that for treachery to be appreciated, the elements of the employment of means of execution giving the victim no opportunity to defend himself and the deliberate adoption of such means must concur. Since Ricardo Nepomuceno's testimony was not credible and no other evidence proved the mode of execution, there was no basis for appreciating treachery. On the presence of evident premeditation: The Court found that evident premeditation was present. The attempt by the accused to borrow a tear gas gun prior to the commission of the crime constituted direct evidence that the killing was planned with care and executed with deliberation. This act showed a previous agreement to kill the victim, and sufficient time had lapsed for reflection, indicating that they clung to their determination. On actual damages: The Court awarded actual damages for funeral and burial expenses amounting to ₱23,800.00, supported by receipts. However, it denied the claim for loss of earning capacity due to insufficient proof, finding the widow's testimony to be self-serving.
Main Doctrine
While an extrajudicial confession obtained without proper constitutional warnings is inadmissible, a judicial confession made in open court, absent any showing of coercion or undue influence, is evidence of high order and can sustain a conviction. Flight and motive are circumstances that can corroborate a confession.