1) Danilo Morada was convicted of murdering 17-year-old Jonalyn Navidad based on circumstantial evidence including an alleged confession, blood-stained clothing, and a bolo found near his home.
2) The Supreme Court reversed the conviction, finding that the alleged extra-judicial confession was inadmissible. Additionally, the blood-stained items were seized without a warrant and their discovery was contrary to human experience.
3) With the confession excluded and issues with the other evidence, the remaining circumstantial evidence was insufficient to prove guilt beyond a reasonable doubt. Morada was acquitted on grounds of reasonable doubt.
1) Danilo Morada was convicted of murdering 17-year-old Jonalyn Navidad based on circumstantial evidence including an alleged confession, blood-stained clothing, and a bolo found near his home.
2) The Supreme Court reversed the conviction, finding that the alleged extra-judicial confession was inadmissible. Additionally, the blood-stained items were seized without a warrant and their discovery was contrary to human experience.
3) With the confession excluded and issues with the other evidence, the remaining circumstantial evidence was insufficient to prove guilt beyond a reasonable doubt. Morada was acquitted on grounds of reasonable doubt.
1) Danilo Morada was convicted of murdering 17-year-old Jonalyn Navidad based on circumstantial evidence including an alleged confession, blood-stained clothing, and a bolo found near his home.
2) The Supreme Court reversed the conviction, finding that the alleged extra-judicial confession was inadmissible. Additionally, the blood-stained items were seized without a warrant and their discovery was contrary to human experience.
3) With the confession excluded and issues with the other evidence, the remaining circumstantial evidence was insufficient to prove guilt beyond a reasonable doubt. Morada was acquitted on grounds of reasonable doubt.
1) Danilo Morada was convicted of murdering 17-year-old Jonalyn Navidad based on circumstantial evidence including an alleged confession, blood-stained clothing, and a bolo found near his home.
2) The Supreme Court reversed the conviction, finding that the alleged extra-judicial confession was inadmissible. Additionally, the blood-stained items were seized without a warrant and their discovery was contrary to human experience.
3) With the confession excluded and issues with the other evidence, the remaining circumstantial evidence was insufficient to prove guilt beyond a reasonable doubt. Morada was acquitted on grounds of reasonable doubt.
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G.R. No.
129723 May 19, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANILO MORADA y TUMLOD, accused-appellant. MENDOZA, J.: FACTS: Danilo Morada was charged, tried and convicted of the crime of murder for the killing of one Jonalyn Navidad in the Municipality of Imus, Cavite. The victim, Jonalyn Navidad, 17, was found, with several hack wounds on the head, near a creek. She was taken to the hospital, but she died shortly after. One SPO3 Gomez (member of PNP Imus) was the first to arrive at the crime scene after receiving the report of the incident. He together with Brgy captain of the place searched the surrounding area and there they found a pair of slippers with a thumbtacks embedded in the insteps where one of the bystanders recognized said pair of slippers as those of Morada. SPO3 Gomez and the Brgy captain therefore proceeded towards the house of appellant Morada and found a stained T-shirt hanging from a tree more or less a meter away from appellants house. He accordingly took said T-shirt as he suspected the red stain on it to be human blood. Also a meter away from the side of the house, he recovered a bolo with a stain on it. The police asked Morada whether he knew anything about the crime, but the latter did not answer and just kept quiet. He then "invited" Morada to the police station for questioning and during oral interrogation, accused admitted that he had hacked Jonalyn Navidad. However, this alleged confession was not taken down into writing allegedly because there was no available lawyer to assist accused-appellant at that time Moradas defense, he testified that he had no knowledge of the crime and interposed a alibi. He also assails the admissibility of the polices statement as to his confession by saying that he was beaten up to make him admit to the killing of Jonalyn Navidad. Appellant has also repeatedly wrote the court and the police while in custody questioning the validity of his arrest and the seizure of his belongings but these were not heeded Ultimately, the trial court rendered its decision finding accused-appellant guilty of the murder of Jonalyn Navidad and imposed on him the penalty of death hence, this automatic appeal where the following issue has been raised: ISSUE: WON the trial court erred in finding him guilty beyond reasonable doubt of the crime of murder based purely on circumstantial evidence?
HELD: YES. The decision of the Imus RTC appealed from is REVERSED and accusedappellant Danilo Morada y Tumlod is ACQUITTED on the ground of reasonable doubt. RATIO: The prosecution, in this case, has presented a number of circumstantial evidence which, taken together, purportedly points to a reasonable moral certainty that the appellant is guilty of killing Jonalyn. However, if some of the circumstances (relied on by the trial court) have not been duly established, the further question is whether the remaining ones are nevertheless sufficient to produce such conviction beyond reasonable doubt? NO. One such circumstantial evidence which must fail the tests provided in the Constitution, Rules of Court and established jurisprudence is the alleged extra-judicial confession of appellant Morada to the police and the Brgy captain. According to the averments of the Bray captain, the appellant sought a private meeting with him, and after the same was granted, appellant accordingly confessed. In the case at bar, it is doubtful whether, as the Brgy Capt claimed, Moradas confession was given divorced from the police interrogation, from the testimony of SPO3 Gomez himself, it would actually appear that the Brgy Capts conversation with the accused was part of the then ongoing police investigation. Since the confession was given without the safeguards in Art. III, 12 and the additional ones provided in RA 7438, particularly the requirement that the confession be in writing and duly signed by the suspect in the presence of counsel, the court held that such confession is inadmissible, and it was error for the trial court to use it in convicting Morada. The Brgy Capts testimony in open court also militate against his averment that appellant had confessed to him his guilt in the crime spontaneously and voluntarily in court. Said Brgy Capt proffered no reason why appellant would want to confess to him (there is no relationship of trust/confidence between them); if he is to be believed that the accused wanted to get out of jail for wanting to talk to him, it is very unlikely for him to actually confess because that would certainly not get him out of jail (contrary to human conduct/nature). Based from the Brgy Capts testimony, it would also appear that Moradas confession as to him was merely hearsay. This is evidenced by his statement that he only learned the reason why the accused allegedly hacked the victim when he asked the prison guard; because if he is to be believed that appellant confessed to him, he could have asked the reason from appellant himself.
With the extra-judicial confession now declared inadmissible, the circumstantial
evidence left should now be tested if they still meet the quantum of proof to sustain appellants conviction? NO. Aside from the confession, another strong circumstantial evidence that the prosecution used against the appellant were the T-shirt and the bolo which had been verified by the NBI to have been stained by human blood. However, it must be noted, as it has been admitted, that these items were confiscated without the proper search warrant. The testimony of SPO3 Gomez and the Brgy Capt to the effect that these items were in plian view is contrary to human experience/nature. The reason is obvious: if these items truly had blood stains on it, it would have been very unlikely to have left just out there for everyone to notice. The police also failed to match the alleged human blood found in these items with that of the victims. Now that the probative value of the T-shirt and the bolo had been put under serious doubt, the only strong circumstantial evidence left for the prosecution is the pair of slippers found at the crime scene which two witnesses identified to belong to the appellant Morada. Suffice it to say that the Court found these witnesses testimonies to be strange, artificial and contrary to human experience. All told, no other strong circumstantial evidence is left to sustain Moradas conviction. Henceforth, he must be acquitted.
