People v. Garde

G.R. No. 103968 (July 11, 1996)

Facts:

The case involves Dimson M. Garde, who, along with Edeme C. Tayapad, was charged with the murder of Noli Diaz on May 14, 1987, in Bacolod City. The information filed against them detailed that both accused, armed with bladed weapons, conspired to kill Diaz, inflicting multiple stab wounds that ultimately led to his death. The prosecution presented evidence that at approximately 4:15 PM on the day of the incident, Diaz was conversing with friends when Tayapad approached him from behind, greeted him, and then stabbed him. Garde subsequently joined in the attack, and both assailants continued to stab Diaz even after he fell to the ground.

The police apprehended Garde and Tayapad shortly after the incident, recovering the weapons used in the attack. Garde later executed an extrajudicial confession admitting his involvement in the crime, which was witnessed by his counsel. During the trial, the defense presented a different narrative, claiming that Garde was not involved in the stabbing and that his confession was coerced by police officers.

The trial court found both accused guilty of murder, sentencing them to reclusion perpetua and ordering them to pay indemnities to the victim's heirs. Garde appealed the decision, contesting both his conviction and the admissibility of his confession.

Legal Issues:

1. Whether the trial court erred in finding Garde guilty beyond a reasonable doubt of murder.
2. Whether Garde's extrajudicial confession was admissible given his claims of coercion and lack of legal counsel during its execution.

Arguments:

• Prosecution's Argument: The prosecution argued that the evidence, including eyewitness testimony and the extrajudicial confession, clearly established Garde's guilt. The eyewitness, Jonathan Balabag, testified that he saw both Garde and Tayapad stab Diaz multiple times. The prosecution maintained that the confession was made voluntarily and corroborated by the physical evidence and medical findings.

• Defense's Argument: Garde's defense contended that he did not participate in the stabbing and that his confession was obtained under duress. The defense highlighted that Garde was not assisted by counsel when he made the confession and claimed he was coerced by police officers. They also pointed out inconsistencies in the prosecution's evidence regarding the number of stab wounds.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding no reversible error in the conviction of Garde. The Supreme Court emphasized the credibility of the eyewitness testimony, which was consistent with the physical evidence and medical findings. The court noted that even a single eyewitness account, if credible, is sufficient for conviction.

Regarding the extrajudicial confession, the court found that it was made with the assistance of counsel and was voluntarily given. Garde's claims of coercion were not substantiated, as he did not file any complaints against the police regarding his treatment. The court concluded that the evidence presented by the prosecution was sufficient to support the conviction, independent of the confession.

The court modified the civil indemnity awarded to the victim's heirs, increasing it from P30,000.00 to P50,000.00 in line with current legal standards.

Significant Legal Principles Established:

1. The sufficiency of a single credible eyewitness testimony can warrant a conviction for serious crimes such as murder.
2. An extrajudicial confession is admissible if it is made voluntarily and with the assistance of legal counsel, and claims of coercion must be substantiated by evidence.
3. The court has the discretion to assess the credibility of witnesses and the weight of evidence presented during trial.