GR L 65792; (March, 1985) (Digest)
G.R. No. L-65792. March 18, 1985
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. CARLOS CRISANTO, JR. and CELIA CRUZ, Accused-Appellants.
FACTS
The victim, Aurea Manaig-Hilario, was fatally stabbed in the back with a balisong knife while inside a jeepney in Manila on May 21, 1979. The medico-legal report confirmed the fatal nature of the single, deep stab wound. Accused-appellants Carlos Crisanto, Jr. and Celia Cruz were convicted of murder by the Regional Trial Court. The prosecution’s case hinged on their extrajudicial confessions, which they later repudiated at trial. Celia Cruz was the girlfriend of the victim’s husband, Dr. Cecilio Hilario, who provided her monthly financial support. The confessions detailed that Celia, along with Ramon Crisanto (Carlos’s cousin), induced Carlos to kill Aurea for a promised payment, motivated by the victim’s control of the family income.
At trial, both accused denied the crime and alleged their confessions were extracted through force and intimidation, claiming they were not properly informed of their rights or allowed to read the statements. The defense presented alibi and denial. The prosecution, however, presented eyewitnesses—the jeepney driver, his wife, and a passenger—who identified Carlos as the assailant. Dr. Hilario also admitted his extramarital affair with Celia, corroborating the motive.
ISSUE
Whether the trial court erred in convicting the accused-appellants of murder based on their extrajudicial confessions and the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s factual finding that the confessions were voluntarily, knowingly, and intelligently given. It found no merit in the claims of coercion, giving credence to the testimonies of the police officers who took the statements. The Court ruled that Crisanto, a first-year college student, and Cruz, a fourth-year high school student, had validly waived their constitutional rights to remain silent and to counsel when they swore to their confessions before the inquest fiscal. Even disregarding the confessions, the positive identification by the eyewitnesses was sufficient to prove Carlos Crisanto, Jr.’s guilt beyond reasonable doubt. The manner of attack—a sudden stabbing in the back of an unarmed and unsuspecting victim inside a stationary jeepney—constituted treachery (alevosia), qualifying the killing as murder. The Court also found the award of civil indemnity, based on the victim’s lost earning capacity, to be proper.