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PEOPLE v. ANTONIO DACANAY Y TUMALABCAB

FACTS:

Antonio T. Dacanay is appealing the decision of the Court of Appeals (CA) affirming his conviction for the crime of parricide. The antecedent facts are as follows: On October 6, 2007, Antonio's wife, Norma Dacanay, was found dead with multiple puncture wounds in their home. Their son, Quinn, discovered the body and alerted their aunt, Beth Bautista. Antonio was not home at the time, as he had gone to work earlier. Quinn informed Antonio about Norma's death and they returned home together where they met with police officers conducting an investigation. During his interview with PO3 Jay Santos, Antonio claimed that a person named "Miller," who he alleged was Norma's lover, might be responsible for the crime. However, the identity of "Miller" was never confirmed. Antonio declined to formalize his statement at the police station, citing the need to arrange Norma's funeral. Two days later, Antonio and Quinn went to the police station where Antonio confessed to the crime before the media and police officers. He admitted to stabbing Norma and staging the crime scene to make it appear as a robbery. Antonio's confession was reported in a local newspaper. At trial, media representatives testified that Antonio voluntarily admitted to the crime, and PO3 Santos confirmed that the missing jewelry was found in Antonio's locker, as he confessed. An autopsy report confirmed that Norma died from multiple stab wounds.

ISSUES:

  1. The sole issue in this case is whether the Court of Appeals erred in affirming the Regional Trial Court's ruling finding the accused guilty of the crime of parricide based on his extrajudicial confession.

  2. Whether the confessions made by the accused to news reporters are admissible as evidence

  3. Whether the confession made by the accused while inside a detention cell is admissible as evidence

  4. Whether the accused's claims of violence and coercion were adequately supported by evidence

  5. Whether the extrajudicial confession of the accused was made freely and voluntarily.

  6. Whether the accused's guilt for the crime of parricide was proven beyond reasonable doubt.

RULING:

  1. The Court of Appeals did not err in affirming the Regional Trial Court's ruling. The accused failed to prove that his extrajudicial confession was given under a coercive atmosphere or that he was under custodial investigation at the time. The confession was found to be voluntary, candid, and straightforward, with no trace of fear, intimidation, or coercion. The Court concluded that the accused's reliance on constitutional safeguards was misplaced, and that his confession was admissible as evidence.

  2. The court ruled that the confessions made by the accused to news reporters are admissible as evidence. The court held that the Bill of Rights only applies to the relationship between the individual and the state, not the relationship between private individuals. In this case, the news reporters acted independently and were not acting under the direction or control of the police. The court also noted that the accused's confessions to the news reporters were witnessed by his family and there was no coercive atmosphere during the interviews. Therefore, the confessions were voluntary and admissible as evidence.

  3. The court ruled that the confession made by the accused while inside a detention cell is admissible as evidence. The court held that the mere fact that the confession was made inside a detention cell does not automatically render it inadmissible. In this case, the accused agreed to be interviewed and answered questions freely and spontaneously. There was no evidence to show that the presence of police officers exerted any undue pressure or influence on the accused. Therefore, the confession was voluntary and admissible as evidence.

  4. The court ruled that the accused's claims of violence and coercion were not adequately supported by evidence. The court noted that the accused failed to present any evidence of compulsion and did not institute any criminal or administrative action against the police officers allegedly responsible. Furthermore, there was no physical evidence of violence presented. The court also pointed out that the accused's son did not testify to any violence or coercion inflicted on his father. Therefore, the court considered these factors as indicating voluntariness and found the accused's claims to be unsupported and uncorroborated.

  5. The accused failed to present any independent evidence of coercion or violence to corroborate his assertion that his confession was coerced or obtained through intimidation. Absent such evidence, the court concluded that the accused's statements were made freely and spontaneously, unblemished by any coercion or intimidation.

  6. All the elements of parricide were present in the case: (1) a person was killed; (2) the deceased was killed by the accused; (3) the deceased was the father, mother, or child, whether legitimate or illegitimate, or a legitimate other ascendant or descendant, or the legitimate spouse of the accused. The fact that the accused's spouse was the deceased was proven through their marriage contract. Moreover, since the accused failed to rebut the presumption of voluntariness regarding the authorship of the crime and the fact of death of his wife, the court found him guilty beyond reasonable doubt for the crime of parricide.

PRINCIPLES:

  • The presumption of voluntariness attends an extrajudicial confession. It is the burden of the accused to overcome this presumption.

  • A confession made before the media does not form part of custodial investigation, but the accused should still be informed of the consequences of confessing.

  • In determining the admissibility of an extrajudicial confession, the court considers whether the confession was made under a coercive physical or psychological atmosphere. If the confession is found to be voluntary, it can be admitted as evidence.

  • Confessions made by an accused to news reporters, in the absence of undue influence from police authorities, are admissible as evidence even if made outside the presence of counsel.

  • The fact that a confession was made by an accused while inside a detention cell does not automatically render it inadmissible as evidence, as long as the confession was given freely and spontaneously.

  • The accused has the burden of proving that a confession was made under duress, and the failure to present evidence of compulsion, institute any action against supposed intimidators, or produce physical evidence of violence may be considered as factors indicating voluntariness.

  • An extrajudicial confession must be corroborated by evidence of corpus delicti to sustain a finding of guilt.

  • Factual findings of the trial court, especially when affirmed by the appellate court, are accorded great weight and respect and should not be disturbed on appeal unless there are facts of weight and substance that were overlooked or misinterpreted and would materially affect the disposition of the case.

  • The court defers to the credibility findings of the trial court in light of their unique opportunity to observe the witnesses and assess their sincerity, spontaneity, demeanor, and behavior in court.

  • In criminal appeals, the court has the authority to review any question in the case, including issues not raised by the parties.

  • The court may award damages to the heirs of the victim even if not granted by the trial court and appellate court, as an appeal in a criminal case opens the entire case for review on any question.