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People of The Philippines, Appellee, vs. Eric Guillermo y GARCIA, Appellant

1) While the appellant's confession to police was inadmissible, this does not necessarily lead to acquittal. 2) The appellant admitted committing the crime to private individuals as well, including calling a security guard immediately after the killing and asking for help disposing of the body. 3) The appellant's statements to the security guard are considered res gestae, or part of the events, and are admissible in court as an exception to hearsay since the statements were made shortly after the crime while still under the influence of the startling event.

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120 views1 page

People of The Philippines, Appellee, vs. Eric Guillermo y GARCIA, Appellant

1) While the appellant's confession to police was inadmissible, this does not necessarily lead to acquittal. 2) The appellant admitted committing the crime to private individuals as well, including calling a security guard immediately after the killing and asking for help disposing of the body. 3) The appellant's statements to the security guard are considered res gestae, or part of the events, and are admissible in court as an exception to hearsay since the statements were made shortly after the crime while still under the influence of the startling event.

Uploaded by

Jai Douglas
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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PEOPLE OF THE PHILIPPINES, appellee, vs.

 ERIC GUILLERMO
y GARCIA, appellant.

Be that as it may, however, the inadmissibility of the appellant’s


confession to SPO1 Reyes at the Antipolo PNP Station as evidence does not
necessarily lead to his acquittal. For constitutional safeguards on custodial
investigation (known, also as the Miranda principles) do not apply to
spontaneous statements, or those not elicited through questioning by law
enforcement authorities but given in an ordinary manner whereby the
appellant verbally admits to having committed the offense. The rights
enumerated in the Constitution, Article III, Section 12, are meant to preclude
the slightest use of the State’s coercive power as would lead an accused to
admit something false.  But it is not intended to prevent him from freely and
voluntarily admitting the truth outside the sphere of such power.
The facts in this case clearly show that appellant admitted the commission
of the crime not just to the police but also to private individuals. According to
the testimony of the security guard, Romualdo Campos, on the very day of the
killing the appellant called him to say that he had killed his employer and
needed assistance to dispose of the cadaver.  Campos’ testimony was not
rebutted by the defense. As the Solicitor General points out, appellant’s
statements to Campos are admissible for being part of the res gestae. Under
the Rules of Court,  a declaration is deemed part of the res gestae and
[48]

admissible in evidence as an exception to the hearsay rule when the following


requisites concur: (1) the principal act, the res gestae is a startling occurrence;
(2) the statements were made before the declarant had time to contrive or
devise; and (3) the statements must concern the occurrence in question and
its immediately attending circumstances. All these requisites are present in
[49]

the instant case. Appellant had just been through a startling and gruesome
occurrence, the death of his employer.  His admission to Campos was made
while he was still under the influence of said startling occurrence and before
he had an opportunity to concoct or contrive a story. His declaration to
Campos concerned the circumstances surrounding the killing of Keyser.
Appellant’s spontaneous statements made to a private security guard, not an
agent of the State or a law enforcer, are not covered by the  Miranda  principles
and, as res gestate,admissible in evidence against him.

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