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stained with blood, and these were taken without any warrant. At the scene of the crime, a pair of
slippers allegedly belonging to Danilo was found. No one directly saw Jonalyn being hacked.)
Issue/Reasoning:
Issue: Whether the circumstantial evidence presented support the conviction beyond reasonable
doubt
- No
- Rule 133, Sec 4 of the Revised Rules on Evidence state when circumstantial evidence is sufficient
for conviction.
As to the alleged confession:
- The alleged confession cannot be used as evidence.
- In People vs Andal, the Court held that the constitutional guarantees during custodial
investigation do not apply to spontaneous statements not elicited through questioning by the
authorities and given during ordinary conversation or during media interviews, whereby the
suspect orally admits the commission of the crime. The ruling in that case does not, however,
authorize the police to obtain confessions they cannot otherwise obtain through media reporters
who are acting for the police.
- In this case, it is doubtful whether Danilo's confession was given divorced from the police
interrogation. SPO3 Gomez himself stated that they interrogated Danilo, and that it was with the
help of Manimbao that Danilo admitted to the killing, and that they were not able to reduce the
confession in writing due to the absence of a lawyer. Manimbao's conversation with Danilo was
part of the then ongoing police investigation. Since the confession was given without the
safeguards in Art III Sec 12 of the Constitution, and the additional ones provided in RA 7438,
particularly the requirement that the confession be in writing and duly signed by the suspect in
the presence of counsel, Danilo's confession is inadmissible.
- Moreover, Manibao's testimony as to the confession is improbable. He testified that Danilo
wanted to talk to him so that he could get out of jail. If that were the case, it was very unlikely
that Danilo would admit his guilt.
As to the shirt and bolo:
- These cannot be used as evidence
- Danilo admits that the shirt and bolo are his, but denies that they were bloodstained when they
were taken from him. It is improbable that these incriminating evidence will be left in public view:
the shirt hanging from a tree, and the bolo in the yard.
- Even if these items were bloodstained, the bloodstain must be shown to match that of the
victim's to sustain conviction.
As to other circumstantial evidence:
- Not enough to sustain conviction.
- Saliva gave his statement to the police on April 16, after Gomez and Manibao executed a joint
statement that they had taken the bloodstained shirt and bolo. Judging by the delay, it appears
that it did not immediately occur to him that Danilo might have something to do with the killing.
- Eric Navidad was interviewed by the police in connection with the killing. It appears that he
never told the police that he recognized the slippers. He only made this claim when he testified in
court.
-Alejandro's identification of the slippers is improbable. Given that he was at his father's wake, it
is unlikely that he was playing with some friends when he saw the slippers. He must be very
observant to notice something in otherwise nondescript sandals.
- There may indeed be suspicion that accused-appellant is the author of the crime. But our legal
culture demands proof beyond reasonable doubt to be established according to law before any
person may be deprived of his life, liberty, or even property. Judgment cannot be rendered on the
basis of mere guesses, surmises, or suspicion. It is not sufficient for a conviction that the evidence
establishes a strong suspicion or a probability of guilt
Dispositive:
Decision appealed from is reversed. Danilo Morada is acquitted on the ground of reasonable
doubt.