G.R. No. 173054; December 6, 2006
PEOPLE OF THE PHILIPPINES, appellee, vs. ELMERCITO MANALO y DULAY, appellant.

FACTS

Before midnight of October 8, 1998, Rosita Estores heard the victim, Ricardo Estores, shouting in pain from his nearby hut. She immediately looked and saw appellant Elmercito Manalo and Rolando Hebreo emerging from the victim’s hut, carrying a jungle bolo and a knife, and proceeding to Manalo’s house. She found the victim lying in a pool of blood. Police responded and surrounded Manalo’s house. After warning shots, Hebreo and then Manalo, with bloodstains on his chest, exited. Manalo admitted to the killing and led police to the concealed weapons. The following day, after being duly informed of his rights and assisted by counsel, Manalo executed an extrajudicial confession before a prosecutor.
At trial, Manalo denied the charges. He claimed he was asleep after a drinking session and was awakened by gunshots, after which he was arrested, mauled, and forced to confess. The Regional Trial Court convicted him of Murder, imposing the death penalty. The Court of Appeals affirmed the conviction but modified the penalty, disregarding the qualifying circumstance of evident premeditation and the aggravating circumstance of dwelling. Manalo appealed, arguing the circumstantial evidence was insufficient and his confession was inadmissible.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction based on circumstantial evidence and his extrajudicial confession.

RULING

The Supreme Court affirmed the conviction but modified the crime to Homicide and the corresponding penalty. The Court held that guilt may be proved by circumstantial evidence when it constitutes an unbroken chain leading to a reasonable conclusion of guilt. The proven circumstances—Manalo was seen fleeing the crime scene with weapons, he had bloodstains, he admitted the killing to police, and the weapons were recovered—formed a coherent chain consistent with his guilt and inconsistent with innocence. The Court found his denial and alibi weak and unsubstantiated.
Regarding the extrajudicial confession, the Court ruled it was admissible. The prosecution established that the prosecutor properly informed Manalo of his constitutional rights, provided him with independent counsel, and ascertained the confession was voluntary, with no signs of coercion. The confession was thus a product of a valid waiver. However, the Court agreed with the Court of Appeals that treachery was not proven, as the attack’s manner was not established. Without treachery, the crime is Homicide, not Murder. The penalty was reduced to an indeterminate sentence of 8 years and 1 day of prision mayor as minimum to 14 years, 8 months and 1 day of reclusion temporal as maximum. Civil indemnity was reduced to P50,000.00, moral damages set at P50,000.00, actual damages of P44,280.00 were affirmed, and the award for exemplary damages was deleted.