Domingo V. De Guzman IIII vs. People of the Philippines (G.R. No. 255100, 255229, 255503, February 26, 2024)
SYLLABUS:
The facts revolve around a conspiracy to kill Enzo Pastor, allegedly orchestrated by his wife Dalia Pastor and her lover Domingo V. De Guzman. The extrajudicial confession of PO2 Angel, despite being recanted, and the testimonies of other witnesses formed the basis for the charges, the issuance of arrest warrants, and the denial of bail for De Guzman. In both the issuance of a warrant and the filing of charges, probable cause requires a reasonable belief, based on facts and circumstances, that the accused is probably guilty of committing a crime. Probable cause is a lower standard than proof beyond reasonable doubt but requires substantial evidence, not mere suspicion or association. Judges have a constitutional duty to independently determine probable cause before issuing a warrant of arrest. They must ensure that there is enough evidence to justify the arrest of the accused, and their determination must be based on the facts of the case rather than mere speculation. In cases involving capital offenses, such as murder, the prosecution must prove that the evidence of guilt is strong to justify the denial of bail. Bail is not a matter of right in these cases, and the court must assess the strength of the prosecution's evidence. A confession that is corroborated by independent evidence is often sufficient to deny bail, even if the confession has been recanted.
FACTS:
Enzo Pastor, a renowned racecar driver, was shot and killed on June 12, 2014, while driving a yellow truck with his mechanic, Paolo Salazar, in Quezon City. According to Salazar, a gunman wearing a mask approached their truck at an intersection and shot Enzo, who later died from the gunshot wound. Salazar survived the attack and testified that the gunman had one "kirat" eye. Shortly after the incident, PO2 Edgar Angel was arrested during a buy-bust operation, and during questioning, he confessed to the murder of Enzo. He claimed that he was hired by Domingo V. De Guzman III, who allegedly conspired with Enzo’s wife, Dalia Pastor, to carry out the murder. Angel stated that Dalia and De Guzman, who were in an illicit relationship, planned the killing because Dalia alleged that Enzo was physically abusing her. However, Angel later retracted his confession, claiming it was coerced.
The prosecution argued that Dalia, as Enzo's wife, had a motive for the killing due to her alleged affair with De Guzman and the claims of domestic violence. The charges against Dalia were based primarily on the testimonies of Angel and other witnesses, including household staff and other individuals who corroborated the affair between Dalia and De Guzman. Despite Angel's recantation, the prosecution maintained that there was enough circumstantial evidence to implicate Dalia in the conspiracy to kill her husband.
Based on Angel's extrajudicial confession and other witness testimonies, the Department of Justice (DOJ) recommended the filing of parricide charges against Dalia and murder charges against De Guzman. The trial court, after evaluating the evidence presented by the prosecution, including the testimonies of witnesses like Paolo Salazar and PO2 Angel’s confession, found probable cause to issue warrants of arrest against both Dalia and De Guzman. The trial court reasoned that the testimonies and evidence were sufficient to establish a prima facie case, enough to bind both Dalia and De Guzman to stand trial. De Guzman was specifically implicated as the mastermind who hired Angel to kill Enzo, while Dalia was accused of conspiring with De Guzman.
Dalia filed a motion to dismiss the charges, arguing that there was no probable cause and that her inclusion in the case was merely based on Angel's unreliable and retracted confession. De Guzman also contested the warrant, claiming that the evidence was insufficient to link him to the murder. However, the trial court denied their motions, prompting both to seek relief from higher courts.
After De Guzman’s arrest in an entrapment operation, he filed an application for bail, arguing that the evidence against him was insufficient and that the charges were based on weak circumstantial evidence and Angel’s coerced confession, which had been retracted. He contended that there was no direct evidence linking him to the crime and that the prosecution’s case relied heavily on Angel’s statements and other witnesses, like Nidua, whose credibility was questionable as a self-confessed gun-for-hire.
The prosecution opposed the bail application, presenting various witnesses, including Salazar, who testified about the circumstances of the shooting, and Nidua, who corroborated the conspiracy between De Guzman and Dalia. The prosecution also highlighted Angel’s confession and the evidence gathered during the entrapment operation, which implicated De Guzman as the mastermind behind the killing. The trial court, after hearing the evidence, denied De Guzman’s bail application, finding that the evidence of his guilt was strong, particularly the corroborated testimonies of Angel and other witnesses.
ISSUES:
1. Whether probable cause exists to charge Dalia Pastor with parricide.
2. Whether the trial court erred in issuing a warrant of arrest against Dalia and De Guzman.
3. Whether De Guzman’s application for bail should be granted.
HELD:
1. Whether probable cause exists to charge Dalia Pastor with parricide:
Probable cause is defined as such facts and circumstances that would lead a reasonably prudent person to believe that a crime has been committed and that the person charged is likely responsible for it. It does not require absolute certainty or proof beyond a reasonable doubt, but merely the likelihood that the crime was committed by the accused.
In dismissing the parricide charge against Dalia Pastor, the Court of Appeals initially ruled that there was insufficient probable cause linking Dalia to the crime. The court emphasized that PO2 Angel’s confession did not explicitly mention Dalia as the mastermind and that any inference of her involvement was speculative. The court also noted that the only connection between Dalia and the crime was her presence during meetings between De Guzman and Angel, which did not automatically prove conspiracy.
The Court’s decision on this issue turned on the requirement that probable cause must be supported by substantial evidence. In this case, the evidence failed to show that Dalia had directly participated in or conspired to commit the crime. The evidence that she had an affair with De Guzman and was allegedly abused by Enzo was deemed insufficient to establish her role as a co-conspirator in the murder. The Court concluded that mere association or circumstantial evidence of her presence during meetings with De Guzman and Angel did not establish probable cause for parricide. The lack of direct or compelling evidence was critical to the dismissal of the case against her.
2. Whether the trial court erred in issuing a warrant of arrest against Dalia and De Guzman:
The Constitution requires that a judge must personally determine probable cause before issuing a warrant of arrest. This determination involves an independent review of the evidence presented by the prosecution to assess whether there is a prima facie case that justifies the arrest of the accused.
The trial court issued warrants of arrest against both Dalia and De Guzman based on its assessment of the evidence presented during the preliminary investigation. The prosecution had provided affidavits, witness testimonies, and PO2 Angel’s extrajudicial confession, which implicated De Guzman as the mastermind behind the murder. The court found this evidence sufficient to establish probable cause for issuing the warrants.
The Court explained that probable cause does not require incontrovertible proof of guilt but must show that there is enough reason to believe that a crime was committed and that the accused is probably guilty. For De Guzman, the court found sufficient evidence to justify the warrant, including Angel’s confession, which was corroborated by other witnesses such as Paolo Salazar and Nidua. In contrast, for Dalia, the court ultimately found that the warrant issued against her lacked sufficient probable cause due to the absence of direct evidence linking her to the crime, leading to the dismissal of the charges against her.
The Court also noted that a judge’s determination of probable cause is not a matter of discretion but a constitutional duty, and it cannot be based on conjecture or speculation. The warrant for De Guzman was upheld as valid, as it was based on an adequate review of evidence, but the one for Dalia was invalidated because the evidence failed to meet the threshold for probable cause.
3. Whether De Guzman’s application for bail should be granted:
Under the Constitution, all persons charged with a non-capital offense are entitled to bail unless the prosecution proves that the evidence of guilt is strong. In capital offenses, such as murder, the burden is on the prosecution to demonstrate that the evidence of guilt is strong in order to deny bail. Bail is a matter of right unless the crime is punishable by death or reclusion perpetua, in which case it becomes discretionary based on the strength of the evidence.
De Guzman applied for bail, claiming that the evidence against him was weak and largely based on a retracted extrajudicial confession. The trial court denied the application, and the Supreme Court affirmed this denial, finding that the prosecution had presented strong evidence of his involvement in the crime. PO2 Angel’s confession, although retracted, was corroborated by other witnesses, including Salazar, who survived the shooting and testified about the circumstances leading to Enzo's death. Additionally, Nidua, a self-confessed gun-for-hire, testified that De Guzman had approached him to kill Enzo, further implicating De Guzman in the conspiracy.
The Court emphasized that the determination of whether bail should be granted in capital offenses is contingent on the strength of the prosecution’s evidence. In this case, the evidence presented, particularly the corroborative nature of Angel’s confession and the testimonies of other witnesses, was sufficient to establish De Guzman’s probable guilt. The retraction of Angel’s confession did not negate its probative value, as the retraction was viewed as inconsistent with the other evidence presented. Furthermore, the rule on res inter alios acta (a confession is only admissible against the confessant and not others) was mitigated by the fact that Angel’s confession was supported by independent evidence that pointed to De Guzman’s culpability. Thus, the denial of bail was justified.
