G.R. No. 70037 , July 7, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEOFISTA BRAGAT VDA. DE CABANGAHAN, accused-appellant.

FACTS

Accused-appellant Teofista Bragat was convicted of parricide for the killing of her husband, Zacarias Cabangahan, on April 8, 1978, by the Regional Trial Court of Lanao del Norte and sentenced to reclusion perpetua. The conviction was based entirely on circumstantial evidence, as there were no eyewitnesses to the crime. The prosecution’s case hinged on Teofista’s alleged voluntary surrender and an extrajudicial confession. A neighbor reported the killing to Pat. Corsino Vicoy, who then found Teofista at the municipal hall. The police blotter entry indicated she surrendered for allegedly killing her husband due to “family trouble.” At the scene, the victim was found with fatal hacking wounds. Pat. Vicoy testified that when he asked Teofista why she killed her husband, she replied that “she can’t bear any more because he was always quarreling with her.” No written statement was taken from her.
The defense presented witnesses to establish an alibi and the victim’s character. One witness testified Teofista was at a prayer meeting from around 8:00 PM to 9:30 PM on the night of the killing. Another neighbor stated he heard loud noises from the couple’s house at around 7:00 PM and again at 10:00 PM when Teofista returned home, after which she asked him to escort her to the municipal building. The defense opted not to present Teofista herself as a witness.

ISSUE

The core issue is whether the circumstantial evidence, particularly the alleged extrajudicial confession and the fact of surrender, is sufficient to prove Teofista’s guilt for parricide beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED Teofista Bragat on the ground of reasonable doubt. The legal logic centers on the insufficiency and inadmissibility of the evidence presented. First, the alleged extrajudicial confession made to Pat. Vicoy is inadmissible. The Court emphasized that for such a confession to be admissible, it must be made with the assistance of competent and independent counsel, which was not done here. The constitutional rights under custodial investigation were violated, rendering the confession void.
Second, the circumstantial evidence fails to meet the required standard of proof. For circumstantial evidence to sustain a conviction, the circumstances must constitute an unbroken chain leading to a fair and reasonable conclusion of guilt, to the exclusion of all other hypotheses. Here, the evidence was broken and inconclusive. There was no proof directly linking Teofista to the murder weapon, no established time of death that placed her exclusively at the scene, and the possibility existed that the crime occurred while she was at the prayer meeting. Her act of going to the municipal station did not necessarily imply guilt but could be consistent with her seeking assistance after discovering the crime. Finally, her decision not to testify cannot be held against her, as the constitutional presumption of innocence and right against self-incrimination remain paramount. The prosecution’s evidence, being weak and inadmissible in part, failed to overcome this presumption.