People v. Capitle

G.R. No. 175330 (January 12, 2011)

Facts:

On August 6, 1993, at approximately 7:40 a.m., Barangay Chairman Avelino Pagalunan was shot and killed by four assailants on Orambo Drive, Pasig City. The incident was witnessed by Ruiz Constantino and Solomon Molino, who were nearby at the time. Pagalunan was rushed to Medical City Hospital but succumbed to multiple gunshot wounds, with the most fatal being to the head.

On the same day, Solomon Molino provided a statement to the police but could not identify the assailants. However, on September 30, 1993, while in custody for another case, Arturo Nagares was identified by Ruiz Constantino from a set of photographs as one of the shooters. Nagares was also identified by another witness, Rodolfo Paat, who claimed to have seen the assailants fleeing the scene.

Nagares later executed an extrajudicial confession implicating Vice Mayor Anching De Guzman as the mastermind and naming Rodolfo Capitle as one of the accomplices. Additional witness statements corroborated the involvement of both Nagares and Capitle in the crime.

The prosecution filed a murder charge against Nagares and Capitle, and both were arraigned on April 17, 1997, entering a plea of not guilty. During the trial, eyewitnesses identified Nagares as one of the shooters, while both accused presented alibis claiming they were elsewhere at the time of the incident. Nagares alleged that his confession was coerced, while Capitle claimed he was at home with his family.

The trial court found both Nagares and Capitle guilty of murder, sentencing them to reclusion perpetua and ordering them to pay damages to the victim's widow. The Court of Appeals affirmed the trial court's decision, leading to the present appeal.

Legal Issues:

1. Whether the constitutional rights of the appellants were violated, rendering the evidence obtained through such violations null and void.
2. Whether the prosecution established the guilt of the appellants beyond a reasonable doubt.

Arguments:

• For the Appellants:

  • Nagares argued that his extrajudicial confession was obtained under duress and without proper legal counsel, violating his constitutional rights.
  • Both appellants claimed alibis that they were not present at the crime scene during the shooting.
  • They contended that the prosecution failed to provide direct evidence linking them to the crime.

• For the Prosecution:

  • The prosecution maintained that Nagares' confession was voluntary and corroborated by eyewitness testimony.
  • They argued that the positive identification of Nagares by witnesses, along with circumstantial evidence against Capitle, was sufficient to establish their guilt.
  • The prosecution asserted that the appellants' claims of torture and coercion were unsubstantiated.

Court's Decision and Legal Reasoning:

The Supreme Court upheld the conviction of both appellants. It ruled that Nagares' extrajudicial confession was admissible as it was given voluntarily, with the assistance of competent counsel, and there was no evidence of coercion. The Court noted that Nagares did not file any complaints regarding alleged maltreatment and that his confession contained detailed information about the crime, indicating its voluntariness.

The Court also found that the positive identification of Nagares by eyewitnesses Ruiz Constantino and Rodolfo Paat was credible and sufficient to establish his involvement in the murder. The Court dismissed the alibi defenses of both appellants, emphasizing that alibis are inherently weak and cannot prevail over positive identification.

As for Capitle, the Court acknowledged that there was no direct evidence linking him to the crime; however, it found sufficient circumstantial evidence to support his conviction. The combination of circumstances, including the eyewitness accounts and the context of the crime, led to the conclusion that Capitle was guilty beyond a reasonable doubt.

Significant Legal Principles Established:

1. The admissibility of extrajudicial confessions hinges on the voluntariness of the confession and the presence of competent legal counsel during the custodial investigation.
2. Positive identification by eyewitnesses is a strong form of evidence that can outweigh alibi defenses.
3. Circumstantial evidence can be sufficient for conviction if it meets the criteria set forth in the Rules of Evidence, specifically that there is more than one circumstance, the facts are proven, and the combination of circumstances leads to a conclusion of guilt beyond a reasonable doubt.