People v. Tizon
REITERATIONFacts
The Antecedents: On May 4, 1997, the naked body of AAA, a 38-year-old woman with a mental imbalance, was discovered in a rice field in Bacolod City. A post-mortem examination revealed multiple contusions, cigarette burns, and signs of sexual intercourse, with the cause of death identified as asphyxia due to strangulation. Evidence found at the scene included a pair of slippers later identified as belonging to accused Nestor Crisostomo. The victim's brother testified to seeing all four accused—Godofredo Tizon, Jr., Randy Ubag, Arnold Ladrillo, and Nestor Crisostomo—drinking together on the night of the incident. Procedural History: Following their apprehension, all four accused executed extra-judicial statements assisted by Atty. Serafin Guinalon. Tizon, Jr.'s statement was an admission placing him at the scene but denying participation in the rape, while the other three confessed to taking turns raping the victim. They were charged with four counts of Rape with Homicide. The Regional Trial Court (RTC) of Negros Occidental, Branch 47, found all four accused guilty beyond reasonable doubt of four counts of rape each and sentenced them to reclusion perpetua for each count. The RTC, however, found insufficient evidence to convict them of homicide as none admitted to the act of strangulation. The Appeal: The accused appealed to the Supreme Court, primarily arguing that their convictions were invalid. They contended that their extra-judicial confessions were inadmissible because they were obtained in violation of their constitutional rights. Specifically, they claimed they were not effectively informed of their rights, did not choose their counsel, and were induced to confess by the police station commander's promise that they would be set free or receive a lighter penalty if they signed the statements.
Issue(s)
Whether the extra-judicial confessions of the accused-appellants are admissible in evidence despite the alleged promise of leniency and the provision of counsel by the police. Whether the defense of alibi is sufficient to overcome the prosecution's evidence. Whether the trial court correctly found the existence of a conspiracy.
Ruling
WHEREFORE, the decision of the Regional Trial Court of Negros Occidental, Branch 47 in Crim. Cases Nos. 97-18381, 97-18554, 97-18555 and 97-18556 is AFFIRMED. Appellants Randy Ubag, Arnold Ladrillo and Nestor Crisostomo are hereby found GUILTY of four counts rape each and, for each count, are each sentenced to suffer the penalty of reclusion perpetua. They are each ordered to pay the heirs of the victim AAA the amount of P200,000.00 as civil indemnity and P200,000.00 as moral damages.
Ratio Decidendi
On the admissibility of the extra-judicial confessions: Yes, the confessions were admissible. The Court found that the appellants were properly informed of their constitutional rights in a language they understood. The counsel provided, Atty. Guinalon, was deemed competent and independent, and his assistance was considered validly engaged because the appellants never objected to his appointment. Crucially, the Court held that the police commander's promise of a lighter penalty did not vitiate the appellants' free will. Citing People vs. De Torres, the Court reasoned that since a police officer has no authority to grant leniency, such a promise is not a valid ground to invalidate a confession. The confessions were also found to be voluntary, detailed, and corroborated by physical evidence. On the defense of alibi: No, the defense of alibi was correctly rejected. The Court reiterated the established rule that for alibi to prosper, the accused must prove that it was physically impossible for them to be at the scene of the crime at the time of its commission. In this case, the appellants' alleged whereabouts were all within a short, walkable distance from the crime scene. Their weak and unsubstantiated alibis could not stand against their own detailed confessions and the corroborating evidence presented by the prosecution, such as the slippers of Nestor Crisostomo found at the scene. On the finding of conspiracy: Yes, conspiracy was properly established. The coordinated acts of the four accused—luring the victim, taking her to a secluded field, collectively overpowering and assaulting her, and taking turns in raping her—clearly demonstrated a common purpose and design to commit the crime. The Court affirmed that where conspiracy is established, the act of one is the act of all. Consequently, each conspirator is liable not only for the rape he personally committed but also for the rapes perpetrated by his co-conspirators, making each of them guilty of four separate counts of rape.
Main Doctrine
An extra-judicial confession is not rendered inadmissible by a promise of leniency, such as a lower penalty, if such promise was made by a police officer who has no authority to grant or comply with it. Such a promise from a non-prosecuting officer is not considered an inducement that vitiates the free will of the accused under the Constitution. Furthermore, a lawyer provided by police investigators during custodial investigation is deemed engaged by the accused if the accused never raises any objection to the lawyer's appointment and proceeds to execute a statement.