G.R. No. 147786. January 20, 2004 (Case Brief / Digest)

### Title: People of the Philippines vs. Eric Guillermo y Garcia

### Facts:

Eric Guillermo y Garcia was charged with the murder of his employer, Victor Francisco Keyser, on March 22, 1998, in Antipolo City, Rizal, Philippines. The charge included the use of a piece of wood and a saw, employing treachery and evident premeditation. Initially pleading guilty, Guillermo later retracted and pleaded not guilty. A trial proceeded in the Regional Trial Court (RTC) of Antipolo City, Branch 73.

Security guard Romualdo Campos witnessed Guillermo entering Keyser Plastics on the day of the murder. Later, Campos heard commotion and was informed by Guillermo of the murder, seeking help to dispose of the corpse. The police were alerted, and upon arrival, found Keyser’s dismembered body after Guillermo surrendered the keys to the premises. Guillermo did not express remorse and justified his actions by alleging maltreatment by Keyser.

Guillermo was interrogated by the Antipolo PNP without being informed of his rights or provided with legal counsel, which he challenged as a procedural violation. Furthermore, his interviews with media reporters where he admitted to the crime were also brought into question regarding their admissibility.

The RTC found Guillermo guilty of murder and sentenced him to death, ordering him to pay significant damages to Keyser’s mother. The decision was automatically reviewed by the Supreme Court due to the imposition of the death penalty.

### Issues:

1. Whether the evidence presented was sufficient to prove Guillermo’s guilt beyond a reasonable doubt.
2. The propriety of imposing the death penalty on Guillermo.
3. The correctness and legality of the damages awarded by the trial court.

### Court’s Decision:

The Supreme Court affirmed the guilt of Guillermo but modified the sentence from death to reclusion perpetua. The Court found several points for legal consideration:
– Guillermo’s confession during police custody was deemed inadmissible due to violation of constitutional rights during custodial interrogation.
– Admissions made to the security guard Campos and media interviews were considered voluntary and part of the res gestae, as they were spontaneous and not elicited through interrogation by authorities.
– Treachery as a qualifying circumstance was not sufficiently proven due to lack of eyewitness testimony on the manner of the attack; however, the act of dismembering the victim’s body was considered as “outraging or scoffing at the corpse,” qualifying the crime as murder.
– The Supreme Court adjusted the damage awards, specifically reducing the amounts for funeral expenses, moral damages, and exemplary damages, and deleted the award for compensatory damages due to insufficient proof. Additionally, civil indemnity and attorney’s fees were awarded.

### Doctrine:

The decision reiterated the doctrine regarding the inadmissibility of confessions obtained without adherence to constitutional rights during custodial interrogation. It also highlighted the criteria for declarations as part of the res gestae and expanded on the elements of treachery in qualifying a crime as murder.

### Class Notes:

– **Custodial Interrogation Rights**: Highlight the necessity for informing an individual of their rights during custodial interrogation, including the right to remain silent and to legal counsel, as per Article III, Section 12 of the Constitution.
– **Res Gestae Admissions**: Note the admissibility of spontaneous statements not elicited by questioning from authorities but made voluntarily to private individuals or media as reflecting the truth of the admission.
– **Qualifying Circumstances for Murder**: Understand that treachery involves means that ensure the execution of the crime without risk to the offender and without allowing the victim to defend themselves, while outraging the corpse of the victim also qualifies the crime as murder.
– **Damage Awards**: Recognize the criteria and justification for awarding civil indemnity, moral damages, exemplary damages, and attorney’s fees in murder cases, along with the adjustments based on evidence and legal standards.

### Historical Background:

This case is situated within the Philippine criminal justice system’s framework for handling severe criminal acts such as murder, emphasizing the rigorous process for ensuring that evidence, especially confessions, adhere to constitutional protections. It also highlights the automatic review by the Supreme Court in cases involving the death penalty, demonstrating the checks and balances in capital punishment cases within the country.


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