Still guilty
Sometimes when a suspect has been caught by the police and undergoes investigation, he may already confess to the crime supposedly committed. And there are also occasions when this suspect may publicly admit his guilt when interviewed by media. But when brought to trial, he may change his mind and disown his confessions. What is the value of these confessions? Can they be used to prove the guilt of the accused? What must be shown in order to make them admissible as evidence of guilt? These will be answered in this case of Leonard.
Leonard is one of the trusted employees of Tony who is the owner and manager of a plastic manufacturing company. One morning, when Tony arrived at his factory he checked the pump motor beside another faucet factory before going to his plastic factory. Then Leonard, who arrived an hour earlier clad in a pair of shorts and naked from the waist up, suddenly appeared and bashed the head of Tony with a piece of wood causing him to fall on the floor where Leonard cut his body into seven pieces using a carpenter’s saw. Afterwards, he mopped up the blood on the floor with plastic foam.
At around noontime, Leonard looked through one of the holes in the dividing wall and calmly told Rod, the security guard assigned in the faucet factory, that he killed Tony and needed his assistance to carry the corpse to the garbage dump where he could burn it. Shocked by the revelation, Rod immediately called the police who instructed him to immediately secure the premises and not allow Leonard to escape. Ten minutes later a police reaction team headed by SPO1 Morabe accompanied by an official police photographer arrived at the crime scene but found the gates of the premises locked. Rod told them that Leonard was still inside, so the officers asked him to open the gate or give them the keys. Leonard acceded, so the officers entered the premises and accosted Leonard who immediately surrendered and pointed to some cardboard boxes where the dismembered limbs and chopped torso of Tony was stuffed.
The police then brought Leonard to the station where they took his statement admitting his guilt without apprising him about his constitutional rights and without providing him with counsel. An NBI medico-legal officer autopsied the remains of Tony. The cruel death shocked the nation such that two TV reporters interviewed Leonard who admitted to one of them that he committed the crime and never gave it a second thought.
When charged with murder, Leonard pleaded guilty assisted by counsel but later on withdrew it. So trial ensued where the prosecution mainly presented Rod who related how Leonard committed the crime and his confession. SPO1 Morabe also testified on how they accosted Leonard and his admission of guilt. The NBI medico-legal officer also confirmed his autopsy report.
Leonard however out-rightly denied his guilt and alleged that he was a victim of police frame-up. He said that he has been an employee of Tony for more than a year as other employees already left due to Tony’s maltreatment. He said that he stayed at the premises the night before for overtime work and fell asleep waiting for Tony to arrive. Sometime later he was awakened when he heard people calling him from the outside and when he looked out he saw persons with firearms telling him they wanted to enter the factory. Once inside they immediately handcuffed him and looked around the premises returning later with boxes and sacks. He was brought to the police station where he was advised to admit his guilt and to face media, instructing him what to say.
The lower court however disbelieved Leonard’s version and convicted him of murder with the maximum penalty of death by lethal injection, and payment of indemnity, damages and attorney’s fees.
On automatic review by the Supreme Court Leonard contended that his conviction was based on inadmissible evidence as there was no clear showing that he was informed of his constitutional rights when he made his confession especially the right to counsel during the custodial investigation.
The SC however said that even if the admission of Leonard during custodial investigation by the police is inadmissible due to lack of the constitutional safeguards, it does not necessarily lead to his acquittal. These safeguards do not apply to spontaneous statements given in an ordinary manner whereby the accused verbally admits having committed the offense.
In this case Leonard also admitted his guilt to Rod who testified that on the very day of the killing Leonard called him to say that he has killed Tony and needed assistance to dispose of the cadaver. This testimony was not rebutted. Furthermore, when Leonard voluntarily agreed to be interviewed on several occasions by TV news reporters acting as media professionals he repeatedly admitted what he had done and even supplied details of Tony’s killing. These spontaneous statements to news reporters during a televised interview are voluntary and admissible in evidence. Leonard’s bare denial given in open court pales in contrast to the spontaneous and vivid out-ofcourt admissions he made to Rod and the two media reporters. The positive evidence consisting of the instruments of the crime and the medical findings, as well as the testimony of other credible prosecution witnesses, leaves no doubt as to Leonard’s guilt. So Leonard is really guilty of murder because he dismembered Tony’s body and sawed off his head, limbs and torso. Since there is no aggravating or mitigating circumstance however, the lesser penalty of reclusion perpetua should be imposed upon him (People vs Guillermo, G.R. 147786, January 20, 2004).