People of the Philippines v.

Adrian Guting y Tomas

GR No. 205412, September 9, 2015

FACTS: On a rainy afternoon of July 30, 2005, at around 5 o’clock, PO1 Fidel
Torre and PO1 Alexis Macusi were standing in front of the Camiling Police
Station when the accused-appellant, all wet from the rain and with a
bladed weapon in his hand, suddenly approached them and told them that
he had stabbed his father. Hearing such statement, PO1 Torre
immediately got the bladed weapon from the accused-appellant and
turned it over to PO1 Macusi for proper disposition. The accused-appellant
proclaimed that his father was already dead. Unsuspecting, PO1 Macusi
asked who killed the victim. The accused-appellant answered, “Sinaksak
ko po yung Tatay ko! Napatay ko po!” PO1 Torre then got the knife from
the accused-appellant and gave to PO1 Macusi who placed the same in
the police station’s custodian cabinet. Thereafter, several officers went to
the residence of Jose Guting to verify the reported crime while other
police officers informed Flora Guting, the victim’s wife about the incident.
SPO2 Felipe inquired from the neighbors if anybody had witnessed the
crime but no one did. Subsequently, Jose was brought to the nearest
hospital where he was pronounced dead on arrival. A complaint against
accused-appellant was then filed for Parricide. On cross-examination, PO1
Macusi divulged that when the knife was given to him by PO1 Torre for
safekeeping, he did not ask the accused-appellant if it was the knife he
used to kill his father. Neither did accused-appellant mention to him that it
was the knife he used in stabbing the victim. The RTC promulgated its
decision on June 24, 2020 finding the accused-appellant guilty of Parricide
based on his verbal admission that he killed his father. Even assuming
that the accused-appellant’s admission was inadmissible in evidence, the
RTC adjudged that the prosecution was able to establish sufficient
circumstantial evidence which, taken collectively, pointed to the accused-
appellant as the perpetrator of the crime. In the CA, the appeal was
denied and the decision of the RTC was affirmed. Hence, this petition to
the SC.

ISSUES: 1. Whether the trial court gravely erred in convicting the accused-
appellant on the basis of his extrajudicial admission;
 2. Whether the trial court gravely erred in convicting the accused-
appellant on the basis on insufficient circumstantial evidence.

HELD: The petition is unmeritorious. The allegation of the accused-appellant that

the evidence is inadmissible for the blatant violation of Sec. 12 of Art. III
of the Bill of rights is incorrect. The SC held that the “investigation” in
Section 12, par. 1 of Article III of the Constitution pertains to custodial
investigation. This commences when a person is taken into custody and is
singled out as a suspect in the commission of a crime under investigation
and the police officers begin to ask questions on the suspect’s
participation therein and which tend to elicit an admission. Applying the
same, the accused-appellant was not under custodial investigation. His
verbal confession was so spontaneously and voluntarily given and was not
elicited through questioning by the police authorities. He was arrested and
subjected to custodial investigation only after his confession. Hence, the
accused-appelant’s confession, even if done without the assistance of a
lawyer, is not in violation of his constitutional right under Section 12 of
Article III of the present Constitution. As to the second issue, the
declaration is admissible as part of the res gestae. All the requisites of the
case are present in this case. His confession was further corroborated by
the circumstantial evidence. Therefore, his conviction is upheld.

Case #11 Vicente H. Manulat, Jr. v. People of the Philippines

GR No. 190892, August 17, 2015

FACTS: Petitioner is the husband of the deceased Genebe Manulat. In the

afternoon of September 4, 2005, Mary Jane Soriano, a neighbor of the
spouses, heard the spouse quarreling. She heard petitioner telling Genebe
“Day, If I get hurt I would box you.” She also heard sounds of breaking
ceramics and a thud, then there was silence. At around 6:40 in the
evening of the same day, petitioner with their two children went to his
mother-in-law Carmen and confided to her the incident. After dinner,
petitioner left his children with his mother-in-law and went home at 11
 o’clock in the evening. The following morning, Carmen, bathed the two
children and asked them what happened. Leslie Kate, their two-year old
daughter answered, “Father threw the cellphone, mother’s mouth bled,”
while Vince Earl, their three-year old son said, “Father choked mama” and
“Mama was left home dead.” Carmen did not mind what the children said
and instead told them that their mother was on duty at Gold City. Around
4 o’clock in the afternoon of the same day, a neighbor rushed to the
house of the spouses upon hearing petitioner’s shout for help. She saw
Genebe hanging from the ceiling on top if the bed Then, petitioner slipped
out the knot and laid the body of his wife on the bed while crying.
Petitioner did not do anything but cry and asked his wife why she had
done it. Around 5 o’clock of the same day, the police officers arrived after
receiving a call from the barangay kagawad pertaining to the incident.
SPO3 Bonifacio Santillana told the petitioner to bring his wife to the
hospital for they might resuscitate her. The petitioner replied that he
could not come with her because he still has to inform his parents-in law.
Santillana detached the rope and noticed that the noose could not be
tightened. Doubting the real cause of death of their daughter, Carmen
and her husband went to the office of CIDG and requested assistance for
the autopsy of the cadaver of Genebe. The Medical Examiner concluded
that Genebe died of asphyxia by strangulation. The RTC rendered a
decision proclaiming the accused guilty beyond reasonable doubt of the
crime charged. Such decision was affirmed by the CA. Hence, this petition
to the SC.

ISSUE: Whether or not the CA erred in affirming the decision of the RTC that
there is sufficient circumstantial evidence exists to establish the guilt of
the accused-petitioner by reasonable doubt.

Held: The SC do not agree with the contentions of the petitioner. Although there
was no eyewitnesses or direct evidence presented that categorically point
to the petitioner as the one who killed his wife, there was also no direct
evidence establishing that the victim took her own life. It is settled that
the lack or absence of direct evidence does of necessarily mean that the
guilt of the accused cannot be proved by evidence other than direct
evidence. The crime charged may be proved also by circumstantial
evidence. In this case, the circumstantial evidence at hand convincingly
prove petitioner’s culpabilities in the crime, and foreclose the possibility
that another person is liable for it or the victim took her own life. The
testimonies of the witnesses and all other circumstantial evidence are
consistent with each other clearly establishing that the victim was killed by
her own husband and not by the claim of the accused that his wife took
his own life. The statements of the petitioner and their children were
spontaneously made. These constitute res gestae. The requisites for the
statements to be classified as res gestae are present in this case. It has
always been said that criminal cases are primarily about human nature.
This is a case of a husband refusing to rush his wife to the hospital even
for the possibility of resuscitation for flimsy reasons that there was nobody
left at their house and that he still had to inform his parent-in-law. It is
noted that from the time he supposedly discovered his wife, he only cried,
he did not exert any effort to rush her to the hospital, and instead, waited
for the police officers to arrive. Such inaction of a supposed loving
husband is contrary to human nature. All considered, the CA did not err in
affirming the trial court’s conclusion that the presumption of innocence of
petitioner has been overcome by the totality of the physical and
testimonial evidence against him.