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PEOPLE v. BERNARDO QUIDATO

FACTS:

Accused-appellant Bernardo Quidato, Jr. was charged with the crime of parricide before the Regional Trial Court of Davao. It was alleged that on September 17, 1988, in the Municipality of Kaputian, Davao, accused-appellant, along with his co-accused Reynaldo Malita and Eddie Malita, assaulted, hacked, and stabbed his father, Bernardo Quidato, Sr., causing his death. Accused-appellant's case was tried jointly with the murder case against his co-accused, but they withdrew their plea during the trial. The prosecution presented witness testimonies, affidavits of the co-accused, and attestation of the due execution of the sworn statements. The prosecution's version of the facts stated that accused-appellant, his father, and the co-accused went to Davao City to sell copra, where the co-accused were paid for their labor. On the evening of September 17, 1988, accused-appellant and the co-accused were drinking at accused-appellant's house, and they planned to rob and kill his father for money. They went to Bernardo's house, where accused-appellant knocked on the door, and when his father opened it, the co-accused attacked and killed him. Accused-appellant's son discovered the body the next day, and upon confrontation, accused-appellant admitted that the co-accused were responsible. The co-accused were arrested, and their unsigned affidavits were presented to a lawyer for advice.

ISSUES:

  1. Whether or not the trial court erred in giving credence to the extrajudicial confessions of Reynaldo Malita and Eddie Malita, thereby violating the constitutional rights of the accused-appellant to confront witnesses.

  2. Whether or not the trial court erred in finding the existence of conspiracy in the case.

  3. Whether or not the trial court erred in disregarding the defense raised by the accused and in disregarding any ill-motive of Reynaldo and Eddie Malita in killing the victim.

RULING:

  1. The extrajudicial confessions of Reynaldo Malita and Eddie Malita were inadmissible as these were hearsay and obtained without the presence of counsel during custodial interrogation, violating the constitutional rights of the accused-appellant.

  2. The finding of conspiracy by the trial court was not upheld due to the inadmissibility of the Malita brothers' extrajudicial confessions since these were made after the conspiracy had ended.

  3. Given the inadmissibility of key evidence brought against the accused-appellant, the defense presented by the accused-appellant should not have been disregarded, resulting in his acquittal.

PRINCIPLES:

  1. Hearsay Rule: Affidavits are inadmissible as evidence unless the affiants testify in court.

  2. Right to Counsel: Uncounseled extrajudicial confessions are inadmissible unless there is a valid waiver of the right to counsel.

  3. Marital Disqualification Rule: A spouse is disqualified from testifying against the other except in criminal cases involving the latter's co-accused.

  4. Evidence in Conspiracy: Acts or declarations of conspirators are admissible against their co-conspirators only if made during the existence of the conspiracy.