CRISOSTOMO v. SANDIGANBAYAN [GR NO. 152398] Case digest

 

CRISOSTOMO v. SANDIGANBAYAN

GR NO. 152398

 

Facts:

Crisostomo, a member of the Philippine National Police and a jail guard at the Solano Municipal Jail was charged with the murder of Renato Suba, a detention prisoner at the Solano Municipal Jail. he Information alleged that Crisostomo conspired with his co-accused, Dela Cruz; Calingayan and others all inmates at the Solano Municipal Jail, in murdering Renato.

The defense adduced that Renato (deceased) hung himself in his detention cell.  Sandiganbayan find the Petitioner guilty for the crime of murder because Crisostomo as jail guard was in such a position that he could have seen or heard the killing.

 

Issue:

Whether or not Sandiganbayan erred in convicting Crisostomo for the crime even there is no direct evidence that will show the participation of Crisostomo on the alleged crime.

 

Held:

Yes.

 

Ratio:

In this case, the prosecution had the burden to prove first, the conspiracy to murder Renato, and second, Crisostomo's complicity in the conspiracy. The prosecution must prove that Renato's death was not the result of suicide but was produced by a deliberate intent to kill him with the attendant circumstances that would qualify the killing to murder. Since Crisostomo had no direct hand in the killing of Renato, the conviction could only be sustained if the murder was carried out through a conspiracy between Crisostomo and his co-accused, the inmates. It must be proven beyond reasonable doubt that Crisostomo's action and inaction were all part of a scheme to murder Renato.

The "deafening silence" of all of the accused does not necessarily point to a conspiracy. In the first place, not all of the accused remained silent. Calingayan put himself on the witness stand. Calingayan further claimed that the Solano police investigated him and his handwritten statements were taken the morning following Renato's death. Secondly, an accused has the constitutional right to remain silent and to be exempt from being compelled to be a witness against himself.