People (Plaintiff-Appellee) vs Danilo Morada y Tumlod (Accused-Appellant) Date: May Date: May 19, 1999 Ponente: Mendoza, Ponente: Mendoza, J. Facts: Danilo Morada was accused of killing Jonalyn Navidad. The prosecution presented witnesses, while the defense presented !, including the accused hi"self. Prosecution: #$%& 'rsenio (o"ez testified that on 'pril 1&, 199, received a phone call that a certain Jonalyn Navidad has )een hacked. 't the scene of the cri"e, (o"ez and )arangay captain *dgardo Mani")ao found a pair of slippers with thu")tacks e")edded in the instep. The slippers were identified )y 'le+andro de la ruz, a )ystander, )ystander, as owned )y Danilo Morada. (o"ez and Mani")ao went to Danilo-s house. They found a stained tshirt, and a stained )olo near the house. /hen they entered the house, Danilo, Danilo-s wife, and Danilo-s )rother were present. Danilo-s )rother said that the slippers )elonged to Danilo. (o"ez then invited Danilo to the police station for 0uestioning. During oral investigation, Danilo ad"itted that he killed Jonalyn, )ut this was not taken down )ecause no lawyer was availa)le availa)le to assist Danilo. The shirt and the )olo were sent to the N2 where it tested positive on the presence of hu"an )lood. (o"ez ad"its t hat the shirt and )olo were taken without warrant. arangay aranga y captain Mani")ao said a version of facts si"ilar to (o"ez. 3e added that Danilo-s wife identified the stained shirt as Danilo-s. 3e also added that at the +ail Danilo wanted to talk to hi", and that Danilo eventually confessed that he owned the slippers, and that he killed Jonalyn. hristopher #aliva testified that on 'pril 1&, 199, he saw Danilo walking away fro" the scene of the cri"e carrying a )olo, and that when Danilo saw hi", Danilo-s face turned pale. #aliva knew )oth Danilo and Jonalyn as they were childhood friends. *ric Navidad, the )rother of Jonalyn, testified that he found Jonalyn-s )ody near a creek. 3e saw a pair of yellow slippers near the )ody, which he identified as Danilo-s. 3e clai"s that the slippers were worn )y Danilo while playing )asket)all. 3e stated that Danilo, although already "arried, was courting Jonalyn. 'le+andro de la ruz testified that on the day of the accident, he was roused )y his wife and was told of the incident. 3e went to the scene where he saw a pair of yellow slippers. 3e identified the slippers )ecause of the thu")tacks. 3e clai"ed that he re"e")ered the slippers )elonging to Danilo as hid the slippers when he and so"e friends played a ga"e during the wake of his father. Defense: Danilo clai"s that at the ti"e of t he incident, he was staying at his house, together with his wife, and that that they had a visitor, 4osita a)anero. 3e clai"ed that earlier that day, Jonalyn-s "other ca"e and sought his help )ecause Jonalyn was found slu"ped in a creek. 3e and his )rother, )rother, Joel, helped Jonalyn-s father to load her into a +eep so that she can )e )rought to the hospital. 3e and his )rother went )ack to his house. &5 "inutes later, later, (o"ez and so"e other police went to his house and arrested hi". 3e clai"ed that the )olo and the tshirt were taken without warrant. warrant. 3e clai"ed that he was )eaten up at the "unicipal )uilding to ad"it to the killing. 3e clai"s that the tshirt taken fro" hi" had no stain at the ti"e it was taken. 3e said that the slippers found in the scene were not his. 3e ad"itted )eing close to Jonalyn, )ut he denied having any special feelings for her her.. 3e clai"s that he is )eing i"plicated in the killing )ecause Jonalyn-s fa"ily wanted to e+ect hi" fro" the land. 4osita a)anero corro)orated Danilo-s testi"ony. Trial: The 4T of Das"arinas, avite found Danilo guilty of "urder and sentenced hi" to death. 2t held that the circu"stanc circu"stances es occurring )efore, during, and after the hacking of Jonalyn, linked together, leads to the conclusion that Danilo "urdered her. Direct appeal to the #. 6Danilo Morada was accused of killing Jonalyn Navidad. 3e was alleged to have confessed to the police and to the )arangay captain that he killed Jonalyn. 3is shirt and )olo were alleged to )e
stained with )lood, and these were taken without any warrant. 't the scene of the cri"e, a pair of slippers allegedly )elonging to Danilo was found. No one directly saw Jonalyn )eing hacked.7 Issue/Reasonin: Issue: Whether the circumstantial evidence presented support the conviction beyond reasonable doubt No 4ule 1&&, #ec 8 of the 4evised 4ules on *vidence state when circu"stantial evidence is sufficient for conviction. 's to the alleged confession The alleged confession cannot )e used as evidence. 2n $eople vs 'ndal, the ourt held that the constitutional guarantees during custodial investigation do not apply to spontaneous state"ents not elicited through 0uestioning )y the authorities and given during ordinary conversation or during "edia interviews, where)y the suspect orally ad"its the co""ission of the cri"e. The ruling in that case does not, however, authorize the police to o)tain confessions they cannot otherwise o)tain through "edia reporters who are acting for the police. 2n this case, it is dou)tful whether Danilo-s confession was given divorced fro" the police interrogation. #$%& (o"ez hi"self stated that they interrogated Danilo, and that it was with the help of Mani")ao that Danilo ad"itted to the killing, and that they were not a)le to reduce the confession in writing due to the a)sence of a lawyer. Mani")ao-s conversation with Danilo was part of the then ongoing police investigation. #ince the confession was given without the safeguards in 'rt 222 #ec 1! of the onstitution, and the additional ones provided in 4' :8&;, particularly the re0uire"ent that the confession )e in writing and duly signed )y the suspect in the presence of counsel, Danilo-s confession is inad"issi)le. Moreover, Mani)ao-s testi"ony as to the confession is i"pro)a)le. 3e testified that Danilo wanted to talk to hi" so that he could get out of +ail. 2f that were the case, it was very unlikely that Danilo would ad"it his guilt. 's to the shirt and )olo These cannot )e used as evidence Danilo ad"its that the shirt and )olo are his, )ut denies that they were )loodstained when they were taken fro" hi". 2t is i"pro)a)le that these incri"inating evidence will )e left in pu)lic view the shirt hanging fro" a tree, and the )olo in the yard. *ven if these ite"s were )loodstained, the )loodstain "ust )e shown to "atch that of the victi"-s to sustain conviction. 's to other circu"stantial evidence Not enough to sustain conviction. #aliva gave his state"ent to the police on 'pril 1<, after (o"ez and Mani)ao e=ecuted a +oint state"ent that they had taken the )loodstained shirt and )olo. Judging )y the delay, it appears that it did not i""ediately occur to hi" that Danilo "ight have so"ething to do with the killing. *ric Navidad was interviewed )y the police in connection with the killing. 2t appears that he never told the police that he recognized the slippers. 3e only "ade this clai" when he testified in court. 'le+andro-s identification of the slippers is i"pro)a)le. ( iven that he was at his father-s wake, it is unlikely that he was playing with so"e friends when he saw the slippers. 3e "ust )e very o)servant to notice so"ething in otherwise nondescript sandals. There "ay indeed )e suspicion that accusedappellant is the author of the cri"e. ut our legal culture de"ands proof )eyond reasona)le dou)t to )e esta)lished according to law )efore any person "ay )e deprived of his life, li)erty, or even property. Judg"ent cannot )e rendered on the )asis of "ere guesses, sur"ises, or suspicion. 2t is not sufficient for a conviction that the e vidence esta)lishes a strong suspicion or a pro)a)ility of guilt Dispositive: Decision appealed fro" is reversed. Danilo Morada is ac0uitted on the ground of reasona)le dou)t.