People vs. Argayan

An extrajudicial confession made to a non-law enforcement officer, voluntarily and not in response to custodial interrogation, is admissible in evidence and, when corroborated by evidence of the corpus delicti, is sufficient to sustain a conviction.

Diane Argayan y Ognayon was charged with parricide for the death of her three-year-old daughter, Jeana Rose Argayan Mangili, on May 26, 2014, in Sablan, Benguet. The prosecution's case rested primarily on the testimony of a six-year-old witness, Raven Rhyzl Cha-ong, who was present at the scene, and the accused's subsequent oral admission of guilt to a social welfare officer.

• Nature of the Case: The accused was charged with parricide under Article 246 of the Revised Penal Code for fatally stabbing her three-year-old daughter, Jeana.
• The Incident: On May 26, 2014, at a residence in Sablan, Benguet, only the accused, the victim Jeana, and a six-year-old witness, Raven, were present. Raven testified that after she went to a garden, she returned to find Jeana by the door crying, with a knife embedded in her back and covered in blood. When Raven asked Jeana who stabbed her, Jeana answered that it was her mother ("ni mama ngamin isu na nang kabil"). The accused, who was present, exclaimed, "Anya syak? (What me?)."
• Accused's Subsequent Actions: The accused removed the knife, cleaned and bathed the victim, changed her clothes, and put her to sleep. She then sent Raven back to the garden. Later, when Raven returned to the house, she found Jeana lying face down on the kitchen floor, dead, with head and back wounds. The accused covered the body with a blanket and cleaned broken glass from the floor.
• Investigation and Confession: Police officers responded to the scene. The cause of death was hemorrhagic shock from multiple stab and hack wounds. The following day, Social Welfare Officer Girlie Willie assisted in taking Raven's statement. Girlie testified that during subsequent visits to provide counseling, the accused, while crying and seeking moral support, admitted to her that she had killed her daughter.
• Defense: The accused waived her right to present evidence.

• Inadmissibility of Confession: Petitioner (accused-appellant) argued that her alleged admission of guilt was inadmissible because it was not made in writing, as required for extrajudicial confessions under custodial investigation.
• Lack of Direct Evidence: Petitioner maintained that no prosecution witness saw her commit the act, and her presence in the garden with Raven at a relevant time made it improbable for her to be the perpetrator.

• Admissibility and Corroboration: Respondent (People of the Philippines) countered that the oral confession was admissible as it was not made during custodial investigation but voluntarily to a social worker seeking support. It was further corroborated by evidence of the corpus delicti.
• Sufficiency of Circumstantial Evidence: Respondent argued that the totality of the credible testimony of Raven, the victim's dying declaration, and the accused's suspicious conduct established an unbroken chain of circumstantial evidence pointing to the accused's guilt.

• Admissibility of Confession: Whether the accused's oral confession to a social welfare officer was admissible in evidence despite not being in writing and made without counsel.
• Sufficiency of Evidence for Conviction: Whether the accused's guilt was proven beyond reasonable doubt through circumstantial evidence and a confession corroborated by the corpus delicti.

• Admissibility of Confession: The oral confession was admissible. The constitutional safeguards under Section 12, Article III and Republic Act No. 7438 apply exclusively to custodial investigation—questioning initiated by law enforcement officers after a person is taken into custody. Here, the confession was made voluntarily to a social worker whom the accused approached for moral support, not in response to any interrogation by authorities. It was an extemporaneous statement, not a product of state coercion.
• Sufficiency of Evidence for Conviction: The conviction was proper. First, the extrajudicial confession was sufficiently corroborated by evidence of the corpus delicti (the fact of the crime), namely the victim's death as established by the death certificate, medico-legal report, and photographs. Second, an unbroken chain of circumstantial evidence existed: (1) only the accused, the victim, and Raven were present; (2) the victim was left alone with the accused; (3) the victim was found stabbed; (4) the victim identified her mother as the assailant; (5) the accused did not refute this; (6) the accused was again left alone with the victim; (7) blood was seen on the accused's feet; and (8) the victim was later found dead. These circumstances, taken together, led to the singular conclusion of the accused's guilt.

• Extrajudicial Confession Outside Custodial Investigation — A confession made to a person not in law enforcement, voluntarily and not in response to interrogation, is admissible even without the safeguards required for custodial investigations (e.g., right to counsel, written form). The constitutional strictures are designed to prevent state coercion, not to inhibit voluntary disclosures.
• Corroboration of Extrajudicial Confession by Corpus Delicti — An extrajudicial confession is insufficient for conviction unless corroborated by evidence of the corpus delicti. Corpus delicti refers to the fact that a crime was committed. Corroboration need not independently prove guilt beyond reasonable doubt; it is sufficient that there is some evidence, apart from the confession, tending to show the commission of the crime.
• Circumstantial Evidence — Conviction can be based on circumstantial evidence if: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt, pointing to the accused to the exclusion of all others.

• "The constitutional procedure on custodial investigation finds no application to an extemporaneous statement, not educed through interrogation by authorities, but given in an ordinary manner where the appellant orally admitted having committed the crime. What the Constitution abhors is the forced disclosure of incriminating facts or confessions." — This passage clarifies the boundary of constitutional safeguards, emphasizing their purpose is to prevent state-compelled confessions.

• People v. Andan, 336 Phil. 91 (1997) — Applied. The Court followed this precedent where a confession made to a mayor, not in response to interrogation and without counsel, was held admissible because it was voluntary and not obtained through state coercion.
• People v. Jugueta, 783 Phil. 806 (2016) — Followed. This case provided the standard amounts for civil indemnity, moral damages, and exemplary damages in cases where the death penalty is not imposed due to Republic Act No. 9346.

• Article 246, Revised Penal Code — Defines parricide and prescribes the penalty of reclusion perpetua to death. Applied to establish the elements of the crime charged.
• Section 12, Article III, 1987 Constitution — Guarantees the rights of a person under custodial investigation, including the right to counsel and the inadmissibility of uncounseled confessions. Interpreted to determine the confession's admissibility.
• Section 3, Rule 133, Rules of Court — Provides that an extrajudicial confession is insufficient for conviction unless corroborated by evidence of the corpus delicti. Applied to assess the sufficiency of the corroborating evidence.
• Section 4, Rule 133, Rules of Court — Enumerates the requisites for circumstantial evidence to be sufficient for conviction. Applied to evaluate the chain of circumstances.

• Associate Justice Alfredo Benjamin S. Caguioa (Ponente)
• Associate Justice Marvic M.V.F. Leonen (Chairperson)
• Associate Justice Henri Jean Paul B. Inting
• Associate Justice Rodil V. Zalameda
• Associate Justice Jhosep Y. Lopez

N/A — The decision was unanimous.