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    Evidence Cases Dianne

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    Jyselle Castro Mercullo
    The Supreme Court upheld the conviction of Vicente Manulat Jr. for strangling his wife Genebe based on circumstantial evidence. Neighbors heard the couple quarreling and sounds of breaking ceramics before silence. Manulat later told his mother-in-law that there was an "incident" but did not rush his injured wife to the hospital. The children also made statements to their grandmother indicating their father choked and hurt their mother. The autopsy found Genebe died of strangulation, inconsistent with Manulat's claim she committed suicide. Taken together, the evidence was sufficient to prove his guilt beyond reasonable doubt.

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    Evidence Cases Dianne

    Uploaded by

    Jyselle Castro Mercullo
    120 views4 pages
    The Supreme Court upheld the conviction of Vicente Manulat Jr. for strangling his wife Genebe based on circumstantial evidence. Neighbors heard the couple quarreling and sounds of breaking ceramics before silence. Manulat later told his mother-in-law that there was an "incident" but did not rush his injured wife to the hospital. The children also made statements to their grandmother indicating their father choked and hurt their mother. The autopsy found Genebe died of strangulation, inconsistent with Manulat's claim she committed suicide. Taken together, the evidence was sufficient to prove his guilt beyond reasonable doubt.

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    The Supreme Court upheld the conviction of Vicente Manulat Jr. for strangling his wife Genebe based on circumstantial evidence. Neighbors heard the couple quarreling and sounds of breaking ceramics before silence. Manulat later told his mother-in-law that there was an "incident" but did not rush his injured wife to the hospital. The children also made statements to their grandmother indicating their father choked and hurt their mother. The autopsy found Genebe died of strangulation, inconsistent with Manulat's claim she committed suicide. Taken together, the evidence was sufficient to prove his guilt beyond reasonable doubt.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    120 views4 pages

    Evidence Cases Dianne

    Uploaded by

    Jyselle Castro Mercullo
    The Supreme Court upheld the conviction of Vicente Manulat Jr. for strangling his wife Genebe based on circumstantial evidence. Neighbors heard the couple quarreling and sounds of breaking ceramics before silence. Manulat later told his mother-in-law that there was an "incident" but did not rush his injured wife to the hospital. The children also made statements to their grandmother indicating their father choked and hurt their mother. The autopsy found Genebe died of strangulation, inconsistent with Manulat's claim she committed suicide. Taken together, the evidence was sufficient to prove his guilt beyond reasonable doubt.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    of 4

    People of the Philippines v.

    Adrian Guting y Tomas

    GR No. 205412, September 9, 2015

    FACTS: On a rainy afternoon of July 30, 2005, at around 5 o’clock, PO1 Fidel
    Torre and PO1 Alexis Macusi were standing in front of the Camiling Police
    Station when the accused-appellant, all wet from the rain and with a
    bladed weapon in his hand, suddenly approached them and told them that
    he had stabbed his father. Hearing such statement, PO1 Torre
    immediately got the bladed weapon from the accused-appellant and
    turned it over to PO1 Macusi for proper disposition. The accused-appellant
    proclaimed that his father was already dead. Unsuspecting, PO1 Macusi
    asked who killed the victim. The accused-appellant answered, “Sinaksak
    ko po yung Tatay ko! Napatay ko po!” PO1 Torre then got the knife from
    the accused-appellant and gave to PO1 Macusi who placed the same in
    the police station’s custodian cabinet. Thereafter, several officers went to
    the residence of Jose Guting to verify the reported crime while other
    police officers informed Flora Guting, the victim’s wife about the incident.
    SPO2 Felipe inquired from the neighbors if anybody had witnessed the
    crime but no one did. Subsequently, Jose was brought to the nearest
    hospital where he was pronounced dead on arrival. A complaint against
    accused-appellant was then filed for Parricide. On cross-examination, PO1
    Macusi divulged that when the knife was given to him by PO1 Torre for
    safekeeping, he did not ask the accused-appellant if it was the knife he
    used to kill his father. Neither did accused-appellant mention to him that it
    was the knife he used in stabbing the victim. The RTC promulgated its
    decision on June 24, 2020 finding the accused-appellant guilty of Parricide
    based on his verbal admission that he killed his father. Even assuming
    that the accused-appellant’s admission was inadmissible in evidence, the
    RTC adjudged that the prosecution was able to establish sufficient
    circumstantial evidence which, taken collectively, pointed to the accused-
    appellant as the perpetrator of the crime. In the CA, the appeal was
    denied and the decision of the RTC was affirmed. Hence, this petition to
    the SC.

    ISSUES: 1. Whether the trial court gravely erred in convicting the accused-
    appellant on the basis of his extrajudicial admission;
    2. Whether the trial court gravely erred in convicting the accused-
    appellant on the basis on insufficient circumstantial evidence.

    HELD: The petition is unmeritorious. The allegation of the accused-appellant that


    the evidence is inadmissible for the blatant violation of Sec. 12 of Art. III
    of the Bill of rights is incorrect. The SC held that the “investigation” in
    Section 12, par. 1 of Article III of the Constitution pertains to custodial
    investigation. This commences when a person is taken into custody and is
    singled out as a suspect in the commission of a crime under investigation
    and the police officers begin to ask questions on the suspect’s
    participation therein and which tend to elicit an admission. Applying the
    same, the accused-appellant was not under custodial investigation. His
    verbal confession was so spontaneously and voluntarily given and was not
    elicited through questioning by the police authorities. He was arrested and
    subjected to custodial investigation only after his confession. Hence, the
    accused-appelant’s confession, even if done without the assistance of a
    lawyer, is not in violation of his constitutional right under Section 12 of
    Article III of the present Constitution. As to the second issue, the
    declaration is admissible as part of the res gestae. All the requisites of the
    case are present in this case. His confession was further corroborated by
    the circumstantial evidence. Therefore, his conviction is upheld.

    Case #11 Vicente H. Manulat, Jr. v. People of the Philippines

    GR No. 190892, August 17, 2015

    FACTS: Petitioner is the husband of the deceased Genebe Manulat. In the


    afternoon of September 4, 2005, Mary Jane Soriano, a neighbor of the
    spouses, heard the spouse quarreling. She heard petitioner telling Genebe
    “Day, If I get hurt I would box you.” She also heard sounds of breaking
    ceramics and a thud, then there was silence. At around 6:40 in the
    evening of the same day, petitioner with their two children went to his
    mother-in-law Carmen and confided to her the incident. After dinner,
    petitioner left his children with his mother-in-law and went home at 11
    o’clock in the evening. The following morning, Carmen, bathed the two
    children and asked them what happened. Leslie Kate, their two-year old
    daughter answered, “Father threw the cellphone, mother’s mouth bled,”
    while Vince Earl, their three-year old son said, “Father choked mama” and
    “Mama was left home dead.” Carmen did not mind what the children said
    and instead told them that their mother was on duty at Gold City. Around
    4 o’clock in the afternoon of the same day, a neighbor rushed to the
    house of the spouses upon hearing petitioner’s shout for help. She saw
    Genebe hanging from the ceiling on top if the bed Then, petitioner slipped
    out the knot and laid the body of his wife on the bed while crying.
    Petitioner did not do anything but cry and asked his wife why she had
    done it. Around 5 o’clock of the same day, the police officers arrived after
    receiving a call from the barangay kagawad pertaining to the incident.
    SPO3 Bonifacio Santillana told the petitioner to bring his wife to the
    hospital for they might resuscitate her. The petitioner replied that he
    could not come with her because he still has to inform his parents-in law.
    Santillana detached the rope and noticed that the noose could not be
    tightened. Doubting the real cause of death of their daughter, Carmen
    and her husband went to the office of CIDG and requested assistance for
    the autopsy of the cadaver of Genebe. The Medical Examiner concluded
    that Genebe died of asphyxia by strangulation. The RTC rendered a
    decision proclaiming the accused guilty beyond reasonable doubt of the
    crime charged. Such decision was affirmed by the CA. Hence, this petition
    to the SC.

    ISSUE: Whether or not the CA erred in affirming the decision of the RTC that
    there is sufficient circumstantial evidence exists to establish the guilt of
    the accused-petitioner by reasonable doubt.

    Held: The SC do not agree with the contentions of the petitioner. Although there
    was no eyewitnesses or direct evidence presented that categorically point
    to the petitioner as the one who killed his wife, there was also no direct
    evidence establishing that the victim took her own life. It is settled that
    the lack or absence of direct evidence does of necessarily mean that the
    guilt of the accused cannot be proved by evidence other than direct
    evidence. The crime charged may be proved also by circumstantial
    evidence. In this case, the circumstantial evidence at hand convincingly
    prove petitioner’s culpabilities in the crime, and foreclose the possibility
    that another person is liable for it or the victim took her own life. The
    testimonies of the witnesses and all other circumstantial evidence are
    consistent with each other clearly establishing that the victim was killed by
    her own husband and not by the claim of the accused that his wife took
    his own life. The statements of the petitioner and their children were
    spontaneously made. These constitute res gestae. The requisites for the
    statements to be classified as res gestae are present in this case. It has
    always been said that criminal cases are primarily about human nature.
    This is a case of a husband refusing to rush his wife to the hospital even
    for the possibility of resuscitation for flimsy reasons that there was nobody
    left at their house and that he still had to inform his parent-in-law. It is
    noted that from the time he supposedly discovered his wife, he only cried,
    he did not exert any effort to rush her to the hospital, and instead, waited
    for the police officers to arrive. Such inaction of a supposed loving
    husband is contrary to human nature. All considered, the CA did not err in
    affirming the trial court’s conclusion that the presumption of innocence of
    petitioner has been overcome by the totality of the physical and
    testimonial evidence against him.

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