People of the Philippines vs. Benjamin Sayaboc y Seguba, Patricio Escorpiso y Valdez, Marlon Buenviaje y Pineda, and Miguel Buenviaje y Flores
### Facts:
On December 2, 1994, Joseph Galam was shot to death at the Rooftop Disco and Lodging House in Solano, Nueva Vizcaya. Earlier in August 1994, Galam had engaged in a fistfight with Marlon Buenviaje, who subsequently threatened to kill him. Eyewitnesses on December 2, 1994, noted Benjamin Sayaboc loitering at the Rooftop and eventually saw him shoot Galam multiple times. Marlon Buenviaje, Miguel Buenviaje, and Patricio Escorpiso were seen nearby in a tricycle and took off with Sayaboc after the crime.
On March 8, 1995, Sayaboc confessed, under alleged coercion and inadequate assistance of counsel, to killing Galam for P100,000 at Marlon Buenviaje’s behest and implicated the other two. Following their arraignment, the trial court found Sayaboc guilty of murder due to treachery, evident premeditation, and sentenced him to death. Marlon was found guilty as a principal in homicide, while Miguel and Escorpiso were found guilty as accomplices.
### Issues:
1. Whether Sayaboc’s conviction for murder was proper.
2. Whether Sayaboc was guilty of homicide rather than murder.
3. Whether Sayaboc’s extrajudicial confession was admissible given alleged issues concerning counsel’s competence.
4. Whether Marlon, Miguel, and Escorpiso’s due process rights were violated.
### Court’s Decision:
– **Issue 1:** The Supreme Court held Sayaboc’s conviction for murder was improper because treachery and evident premeditation were not sufficiently proven. The initial shots at Galam from behind were inferred, not witnessed, thereby not substantiating treachery. The exact plan’s formation was unclear, negating evident premeditation.
– **Issue 2:** Sayaboc was found guilty of homicide, as the killing lacked the qualifying or aggravating circumstances necessary for a murder conviction. Craft and price/reward, though proven, were not alleged explicitly in the information, requiring reduction to homicide.
– **Issue 3:** Sayaboc’s extrajudicial confession was deemed inadmissible. The Court found that Sayaboc’s right to a competent and independent counsel was violated; his counsel was neither vigilant nor independent, given the passive role during custodial investigation.
– **Issue 4:** Marlon, Miguel, and Escorpiso’s contentions of due process violations weren’t deemed valid. The submission of a demurrer to evidence without leave of court represented a waiver of their right to present evidence, leading to dictated judgment based on the prosecution’s evidence alone.
### Doctrine:
1. **Right to Counsel:** The proper waiver of the right to remain silent during custodial investigation requires the informed assistance of a competent, independent, and vigilant counsel. Any deficiencies render extrajudicial confessions inadmissible.
2. **Insufficient Evidence for Qualifying Circumstances:** Without clear and compelling evidence indicating treachery or evident premeditation, the higher charge of murder cannot be sustained.
3. **Retroactivity of Procedural Rules:** Aggravating circumstances must be alleged explicitly in the information for their consideration, and changes in procedural rules favoring the accused apply retroactively.
### Class Notes:
– **Key Elements for Homicide vs. Murder:**
– **Murder:** Requires qualifying circumstances like treachery, evident premeditation.
– **Homicide:** Killing with neither mitigating nor aggravating circumstances.
– **Competent Counsel:** The presence of counsel must involve active engagement ensuring the accused’s understanding of rights and consequences.
– **Section 8, Rule 110 (2000):** Aggravating circumstances must be part of the information for due process protection.
### Historical Background:
This case occurred during the early application period of the 1987 Philippine Constitution’s provisions on rights during custodial investigation, highlighting the stringent standards for valid confessions and procedural requirements in criminal proceedings. The specific fact matrix also depicts societal issues surrounding witness protection, police practices, and the treatment of extrajudicial confessions.
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