People v. Constancio
REITERATIONFacts
The Antecedents: On March 11, 2001, the victim "AAA" was abducted outside Alabang Town Center by Nieves Constancio, Ernesto Berry, and three others. She was taken to Constancio's house, where she was raped and strangled to death. Her body was subsequently thrown over a bridge in San Antonio Valley, Parañaque City. A witness, Chito Adarna, observed Constancio and Berry disposing of a body from a black Mazda car belonging to the victim. Another witness, Janette Bales, identified Berry as the person who attempted to abduct her using the same car the following night. Procedural History: Constancio and Berry were arrested following an informant's tip. During custodial investigation, Berry executed a Sinumpaang Salaysay (extrajudicial confession) with the assistance of Atty. Rhonnel Suarez. He also confessed his involvement during a televised interview with ABS-CBN reporter Dindo Amparo. The Regional Trial Court (RTC) of Parañaque City, Branch 258, found both guilty of Rape with Homicide, while acquitting co-accused Pagkalinawan for lack of positive identification. The Court of Appeals (CA) affirmed the conviction. The Appeal: The appellants filed a notice of appeal before the Supreme Court, challenging the credibility of the prosecution witnesses. They argued that Berry's extrajudicial confession was inadmissible because Atty. Suarez was not a competent and independent counsel of Berry's choice. Furthermore, Constancio argued that Berry's confession should be excluded as against him under the principle of res inter alios acta, asserting that the rights of a party cannot be prejudiced by the declaration of another.
Issue(s)
Whether the testimonies of prosecution witnesses Bales and Adarna are credible and sufficient for positive identification. Whether Berry's extrajudicial confession (Sinumpaang Salaysay) is admissible despite challenges to the competence and independence of his counsel. Whether Berry's televised interview with a news reporter is admissible in evidence. Whether Berry's extrajudicial confession can be used as evidence against his co-accused Constancio under the res inter alios acta rule.
Ruling
The appeal is DENIED. The Decision of the Court of Appeals is AFFIRMED with MODIFICATIONS that appellants are ordered to solidarily pay the heirs of "AAA" civil indemnity, moral damages, and exemplary damages in the increased amounts of P100,000.00 each, with interest at the rate of 6% per annum from finality of the Decision.
Ratio Decidendi
On Issue 1: The Court upheld the credibility of witnesses Bales and Adarna, noting that factual findings of the trial court affirmed by the Court of Appeals are entitled to great weight. The appellants failed to demonstrate that the lower courts overlooked material facts or misconstrued circumstances that would radically affect the outcome. Adarna's identification of the appellants disposing of the body and Bales' identification of Berry during a subsequent attempted abduction were deemed positive and reliable. The Court emphasized that the trial court had the unique opportunity to observe the deportment and demeanor of the witnesses. Consequently, the defenses of alibi and denial were rejected in light of this positive identification. On Issue 2: Berry's extrajudicial confession is admissible as it met all constitutional requirements under Article III, Section 12. The Court found that Atty. Suarez was a competent and independent counsel who was chosen by Berry himself at the police precinct. Atty. Suarez testified that he thoroughly explained Berry's constitutional rights and the consequences of his statements before the confession was signed. There was no evidence that the counsel was remiss in his duties or that the investigation was conducted under duress. The Court ruled that in the absence of proof to the contrary, the custodial investigation is presumed to have been regularly conducted. On Issue 3: The televised confession to news reporter Dindo Amparo is admissible because it was made spontaneously and voluntarily. Statements made by a suspect to news reporters are not considered part of a custodial investigation conducted by police authorities or investigating officers. As established in People v. Andan, such confessions do not require the presence of counsel to be admissible because they are not the result of state-coerced interrogation. There was no proof that Berry's narration to the reporter was the product of intimidation, thus making the interview a valid piece of evidence against him. On Issue 4: While the general rule of res inter alios acta under Rule 130, Section 28 states that a party's rights cannot be prejudiced by the declaration of another, an exception applies here. An extrajudicial confession may be used against a co-accused as circumstantial evidence to show the probability of their participation if corroborated by other evidence. In this case, Constancio was positively identified by Adarna as one of the persons throwing the body over the bridge and riding in the victim's car. This circumstantial evidence, when taken together with Berry's confession, establishes Constancio's guilt beyond reasonable doubt. The Court found that Berry acted as a co-conspirator by direct participation in disposing of the body, making the act of one the act of all.
Main Doctrine
An extrajudicial confession is admissible if it is voluntary, made with the assistance of competent and independent counsel, express, and in writing. Spontaneous statements made by a suspect to news reporters during a televised interview are deemed voluntary and are admissible in evidence because they are not the result of a custodial investigation conducted by police authorities. While the res inter alios acta rule generally provides that an extrajudicial confession is binding only on the confessant, it may be admitted against a co-accused as circumstantial evidence to show the probability of their participation when corroborated by other independent evidence.