Case #10 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 oclock, 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 stations 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 victims 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 crossexamination, PO1 Macusi divulged that when the knife was given
to him by PO1 Torre for safekeeping, he did not ask the accusedappellant 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-appellants 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 accusedappellant 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 suspects 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-appelants 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
oclock 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, mothers mouth bled, while Vince Earl, their threeyear 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 oclock in the afternoon of the same day, a neighbor
rushed to the house of the spouses upon hearing petitioners
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 oclock
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 petitioners 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 courts
conclusion that the presumption of innocence of petitioner has
been overcome by the totality of the physical and testimonial
evidence against him.