GR 113684; (January, 2000) (Digest)
G.R. No. 113684 . January 25, 2000.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARMANDO GALLARDO y GANDER, ALFREDO COLUMNA y CORREA, and JESSIE MICATE y ORTEZA, accused-appellants.
FACTS
Accused-appellants Armando Gallardo and Alfredo Columna, together with Jessie Micate, were charged with the murder of Edmundo Orizal. The prosecution’s case was anchored primarily on the extra-judicial confessions executed by Gallardo and Columna before Police Investigator SPO4 Isidro Marcos. In their detailed confessions, they admitted that they, along with Micate, shot and killed Orizal. They claimed the killing was upon the instigation of a certain Pat. Molina, who relayed the desire of Congressman Domingo Tuzon to have Orizal eliminated due to political rivalry. The confessions were taken with the assistance of Atty. Rolando Velasco and sworn to before Judge Vilma Pauig.
During trial, accused-appellants repudiated their confessions, alleging they were extracted through force, intimidation, and maltreatment by the police. They testified that they were not properly informed of their constitutional rights and that the lawyer provided did not meaningfully assist them. The trial court, however, found their testimonies denying the voluntariness of the confessions unconvincing and gave full credence to the prosecution’s evidence.
ISSUE
Whether the extra-judicial confessions of accused-appellants are admissible as evidence, having been voluntarily executed with the assistance of counsel and in compliance with constitutional requirements.
RULING
The Supreme Court affirmed the trial court’s decision, upholding the admissibility of the confessions. The legal logic rests on the presumption of regularity in the performance of official duty by the police officers and the administering judge. The Court found that the defense failed to present clear and convincing evidence to overcome this presumption. The presence of Atty. Velasco during the investigation and of Judge Pauig during the oath-taking substantiated compliance with the constitutional rights to counsel and to be informed of such rights. The claim of coercion was deemed a mere afterthought, especially since no medical evidence or timely complaint was presented to corroborate the alleged maltreatment.
Furthermore, the confessions contained rich details of the crime that could only be known to the perpetrators, indicating voluntariness. The trial court’s assessment of witness credibility, including its rejection of the appellants’ denial, was accorded great weight. Consequently, the confessions, being admissible and corroborated by other evidence, sufficiently established guilt beyond reasonable doubt. The Court, however, reduced the moral damages awarded and referred the matter concerning the alleged masterminds to the Department of Justice for further investigation.