PEOPLE V.

ERIC GUILLERMO

Employee CHOP-CHOPS abusive employer

FACTS:

Guillermo has been found guilty of murder by the Trial Court of Antipolo City with evident premeditation
and treachery thereby sentencing him to suffer death penalty. The facts show that Guillermo killed his
employer Victor Keyser, owner of Keyser Plastics, by hitting him with a piece of wood and thereafter
cutting his limbs with a carpenter’s saw.

Keyser Plastics shares its building with Greatmore Corp. where prosecution witness Campos is employed
as a security guard. According to Campos, the spaces of the two companies are separated by a wall, the
lower part of which is made of cement but the upper part is made of lawanit boards. The upper part made
of lawanit has two large holes which would allow a person on one side of the wall to see the other side.
He further said that on the day of the crime, he both saw the accused and the victim enter the premises of
Keyser Plastics at around 8:00 am. At around 10:00 am, he heard some loud noises from Keyser Plastics
but he did not pay attention thinking it was just the sound from the machines. He was, however,
interrupted when the accused looked through one of the holes and calmly told him that the accused has
killed his employer and needed help in disposing the body. Shocked by this, Campos immediately called
the police.

After succeeding in persuading Guillermo to give them the keys to the locked gate, the police accosted
the accused who told them “Sir, hindi ako lalaban, susuko ako, haharapin ko ito.” When asked where the
victim’s body was, Guillermo pointed to some cardboard boxes where the dismembered limbs and
chopped torso was found, while the victim’s head was inside a cement bag. When the police asked
how he did it, the accused answered that he first hit the head of the victim and then dismembered the
body. The accused then turned over a blood-stained coconut lumber and a saw. When asked as to his
motive, he answered that Keyser had been maltreating him and his co-workers. He expressed no regret
for his actions. At the police station, however, the custodial investigation was conducted without
appraising the accused of his constitutional rights and his right to counsel.

While in police custody, Guillermo was interviewed on separate occasions by two TV reporters, namely:
Gus Abelgas of ABS-CBN and Kara David of GMA. Appellant admitted to David that he committed the
crime and never gave it second thought. He also disclosed to David the details of the crime. When asked
why he killed his employer, Guillermo stated that Keyser had not paid him for years, did not feed him
properly, and treated him like an animal. Both Abelgas and David said that Guillermo expressed
absolutely no remorse over his alleged misdeed during the course of their respective interviews with him.

During the trial, Guillermo’s defense consisted of denial, that he was a victim of a police frame-up. He
said that he was a stay-in employee and that on the day of the crime, he was asked to work overtime
during the afternoon. Since his employer did not arrive, he fell asleep and was awakened by the police
asking him to open the gates. According to him, the police immediately handcuffed him and looked
around the premises and returned carrying boxes and sacks. He said he was then brought to the police
station where he was advised to admit having killed his employer since there was no other person to be
blamed. When he was made to face the media reporters, he said the police instructed him what to say.

Having been sentenced to suffer the penalty of death, Guillermo’s case was brought for automatic review
to the SC.

ISSUES:

1) Whether or not the prosecution’s evidence is sufficient to prove the accused’s guilt beyond reasonable
doubt
2) Whether or not the death penalty is appropriate in accused’s case
RULING:

1) Yes.

The accused contends that any evidence gathered from him during the custodial investigation, including
his confession, is inadmissible due to the fact that he was not properly informed of his rights. He was only
made to read said rights in the wall of the precinct.

The contention has merit. However, there are other instances, aside from the custodial investigation, that
accused had voluntarily admitted the crime, namely:
1) First, he admitted the crime to Campos, whose testimony was not countered by the defense.
2) Second, he admitted the crime to members of the media on two separate occasions.
3) Third, he voluntarily confessed before the police could enter the scene and before any questions
were posed to him.

Therefore, while the confession during the custodial investigation is inadmissible because of the disregard
of the accused’s constitutional rights, the other instances wherein he admitted to committing the crime are
admissible since the rights enumerated in the Constitution are meant to preclude the slightest use of the
States coercive power as would lead an accused to admit something false but are not intended to prevent
him from freely and voluntarily admitting the truth outside the sphere of such power.

2) No.

The aggravating circumstances of evident premeditation and treachery were not sufficiently
proven.

The autopsy revealed that the traumas in the head were found on the front, left, and right side of the head
but none were found at the back of the head. Moreover, there was no witness to testify as to how the
head was hit by the accused.

Qualifying circumstance of outraging or scoffing at the corpse

One attendant circumstance, however, is amply proved by the prosecutions evidence which shows that
the victims corpse was sewn by appellant into 7 pieces. Under the RPC, outraging or scoffing at the
corpse is a qualifying circumstance. Dismemberment of a dead body is one manner of outraging or
scoffing at the corpse of the victim. In this case, the corpse of the victim was dismembered by the
accused who sawed off the head, limbs, and torso. The Information categorically alleges this qualifying
circumstance, when it stated that the appellant thereafter, cut into pieces using said saw one Victor
Keyser. This being the case, as proved by the prosecution, accused is guilty not just of homicide but of
murder.

The penalty for murder is reclusion perpetua to death. There being neither aggravating nor mitigating
circumstances in the instant case, the lesser penalty of reclusion perpetua should be imposed upon
accused.

(Damages reduced: Moral damages P500k to P50k, exemplary P300k to P25k, compensatory P500k
deleted because of lack of proof, civil indemnity P50k, and attorney’s fees P25k.)