G.R. No. 206296 , August 12, 2015
People of the Philippines, Plaintiff-Appellee, vs. Rodolfo Omilig y Mancia, Anacleto C. Matas, Jr., Ramil Peñaflor, and Oscar Ondo, Accused. Ramil Peñaflor y Laput, Accused-Appellant.

FACTS

An Information was filed against Rodolfo Omilig, Anacleto C. Matas, Jr., Ramil Peñaflor, and Oscar Ondo for the murder of Eduardo Betonio on August 21, 1993, in Iligan City. The prosecution alleged conspiracy, with the accused armed with a firearm and a hunting knife, attacking Betonio with treachery and evident premeditation. Betonio, the Provincial Manager of the National Food Authority (NFA) in Lanao del Norte, had suspended accused Matas due to unaccounted rice stocks discovered by a COA auditor. On the evening of August 21, 1993, Betonio was stabbed and shot in front of his residence. His widow, Vicenta Betonio, heard him shout and later heard gunshots. Before dying, Betonio whispered the names “Delfin and Matas.” The investigation led to accused-appellant Ramil Peñaflor, who gave two extrajudicial confessions on November 12 and 15, 1993, admitting to the killing and stating he was hired by accused Ondo for P15,000.00. The confessions were taken with the assistance of counsel de officio (Attys. Neferteri Salise-Cristobal and Floro Cavales). The defense contested the admissibility of these confessions, arguing violation of Peñaflor’s right to counsel of his own choice, as his family had engaged Atty. Gerardo Padilla after the first confession. The Regional Trial Court (RTC) convicted Peñaflor of murder based on his extrajudicial confessions but acquitted his co-accused for lack of evidence. The Court of Appeals affirmed the conviction.

ISSUE

The primary issue is whether the extrajudicial confessions of accused-appellant Ramil Peñaflor are admissible in evidence, considering the alleged violations of his constitutional right to counsel.

RULING

The Supreme Court affirmed the conviction. The Court held that the extrajudicial confessions were admissible and voluntarily given. It found that accused-appellant Peñaflor was properly assisted by competent and independent counsel during the taking of his confessions. The lawyers present were not acting under the control of the police or prosecutor and adequately explained his rights to him. The fact that his family had engaged a private counsel after the first confession did not render the second confession inadmissible, as he had already discharged the private counsel before executing it. The Court found the confessions detailed, replete with facts only the perpetrator would know, and corroborated by other evidence, such as the medical findings and the testimony of the victim’s widow. The Court affirmed the penalty of reclusion perpetua and modified the damages awarded, ordering Peñaflor to pay the heirs of Betonio P75,000.00 as civil indemnity, P75,000.00 as moral damages, P30,000.00 as exemplary damages, and P25,000.00 as temperate damages, all with 6% interest per annum from finality until fully paid.