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PEOPLE v. EDWIN DE VERA Y GARCIA

FACTS:

The case involves the murder of Frederick Capulong on June 8, 1992, in Quezon City, Philippines. The accused were charged with murder in an Information. The prosecution alleged that the accused conspired and confederated to attack and kill Capulong. An eyewitness testified for the prosecution, stating that he saw the victim being dragged out of a car by one of the accused, who then shot him between the eyes. The trial court found two of the accused guilty beyond reasonable doubt of murder and sentenced them to reclusion perpetua. Only one of the accused filed a Notice of Appeal.

Ten minutes after the shooting incident, police officers arrived at the scene to investigate. They found blood stains and damaged grass near the site of the shooting. The victim was brought to the hospital, and the police officers found a red sports car with the victim's belongings inside. They also found a person near the clubhouse who claimed to be a victim of a hold-up. Suspecting his conduct, the police officers brought him to the station for investigation. The appellant admitted his involvement in the crime and implicated another person. The police officers recovered the gun, a black t-shirt, and a black cap. They prepared a sketch of the crime scene and returned to the station, where the appellant and another person gave written statements with the assistance of a lawyer.

The case involves the killing of Ramyl Cuedo. The victim's body was found with multiple gunshot wounds. The police investigation led to the arrest of several suspects, including the appellant. The appellant claimed that he had no part in the killing and that it was another suspect who shot the victim. The appellant alleged that he was tortured and coerced into signing a statement regarding the incident. The suspects underwent paraffin testing, which yielded positive results for the appellant and negative results for another suspect. Surveillance and follow-up operations were conducted against the other suspects, but they were not arrested or brought to trial.

The case involves the appellant, who was charged with murder and frustrated murder. The victims were found dead inside their bedroom. The appellant was identified by a witness as the person seen leaving the crime scene. Subsequently, he was arrested and brought to the police station for questioning. During the investigation, the appellant executed an extrajudicial confession in the presence of his counsel, admitting to entering the victims' house with the intent to rob them but denying killing them. Based on this confession, the police filed the corresponding criminal charges against the appellant. The trial court convicted the appellant of murder and frustrated murder, ruling that the identification evidence was credible and that the confession was voluntarily made. The appellant appealed the decision, questioning the admissibility of the identification evidence and his extrajudicial statement, as well as his liability.

ISSUES:

  1. Whether the prosecution eyewitness Bernardo Cacao testified to any criminal act of the appellant.

  2. Whether the trial judge erred in finding that there was a conspiracy to kill the victim and that the appellant was a co-conspirator.

  3. Whether the trial judge erred in admitting the extrajudicial statement of the appellant, given the manner in which it was obtained.

  4. Whether the prosecution proved the appellant’s guilt beyond reasonable doubt warranting his acquittal.

RULING:

  1. First and Third Issues The prosecution evidence, specifically the eyewitness testimony of Bernardo Cacao, failed to establish beyond reasonable doubt that the appellant was a principal in the conspiracy to kill the victim. The appellant's extrajudicial statement, although implicating him as an accomplice, was ruled admissible. As such, the appellant was convicted only as an accomplice, not as a principal in the crime.

  2. Second Issue The Supreme Court found that the appellant’s extrajudicial statement met constitutional requirements. The assertions of torture and lack of counsel were rejected, substantiated by the testimony of Atty. Confesor Sansano. Hence, the extrajudicial confession was deemed voluntary and credible, making it admissible.

  3. Fourth Issue The Court found that sufficient prosecution evidence established the appellant's criminal liability as an accomplice, confirming his presence at the crime scene to act as a lookout, but not as a co-conspirator.

PRINCIPLES:

  1. Proof of Conspiracy Conspiracy must be established beyond reasonable doubt, with evidence supporting a common design to commit a crime.

  2. Standard of Criminal Liability An accomplice is defined as one who participates knowingly in the criminal design but does not partake in the initial planning or execution of the crime.

  3. Voluntariness and Credibility of Extrajudicial Confessions Confessions must conform to constitutional safeguards and be free from coercion, with a presumption of voluntariness if these requirements are satisfied.

  4. Evidentiary Requirements Extrajudicial confessions require corroboration by evidence of corpus delicti, showing that a crime occurred and a person is criminally responsible.

  5. Penalty Distinction The liability of a principal is collective, while the liability of an accomplice is one degree lower than that of a principal, reflecting their lesser degree of participation.

  6. Absorption of Aggravating Circumstances Treachery absorbs abuse of superior strength as an aggravating circumstance.

  7. Moral Damages and Indemnification Awards must be supported by evidence, with moral damages provided for substantial emotional distress, and compensatory damages reflecting actual losses incurred.