G.R. No. 91015 December 23, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DAQUILLO MANIA y LINAZA, defendant-appellant.

FACTS

On November 1, 1988, Eduardo Lim, a supervisor of Anchorage Wood Industries, Inc. (AWII), discovered the body of company guard Juanito Palsagingin with hack and stab wounds at the company logpond. The company bodega was forcibly opened, and a Stihi chainsaw was missing. Police investigation led by P/Sgt. Felix Plaza, Jr. ensued. Information from Barangay Captain Romulo Bantayan indicated that Guadalupe Garay had knowledge about the incident. Garay revealed that accused-appellant Daquillo Miana and Israel Dapitanon borrowed her flashlight on the night of October 31, 1988. A fishing spear was also found at the scene. Accused-appellant was arrested on November 3, 1988. At the police station, Pat. Antonio Lagura, Jr. questioned him without counsel, and accused-appellant allegedly confessed to the killing and theft, implicating Dapitanon and stating the chainsaw was hidden on Buhangin Island. Dapitanon was also arrested and confessed, leading the police to recover the chainsaw from Buhangin Island. An information for robbery with homicide was filed. During arraignment, Dapitanon pleaded guilty, while accused-appellant pleaded not guilty. The prosecution presented Sgt. Plaza, Pat. Lagura, barangay captain Bantayan, and Eduardo Lim. The defense was alibi, with accused-appellant claiming he was working in Davao City during the crime and was only in Lingig to get fish when arrested. Israel Dapitanon testified that his companions in the crime were Bobong Cero and Rey Padilla, not accused-appellant. The trial court convicted accused-appellant.

ISSUE

Whether the conviction of accused-appellant Daquillo Miana for robbery with homicide is valid based on the evidence presented.

RULING

No. The Supreme Court reversed the trial court’s decision and acquitted accused-appellant. The alleged extra-judicial confession of accused-appellant was obtained during custodial investigation without the assistance of counsel, in violation of his constitutional rights under Article III, Section 12(1) of the 1987 Constitution, rendering it inadmissible in evidence. Without this confession, the conviction could not stand. The physical evidence (hammer, flashlight, fishing spear, bolo) was not recovered from or linked to accused-appellant. The information leading to the recovery of the chainsaw came from Dapitanon, who also led the police to it. The testimonies regarding Guadalupe Garay’s information were hearsay, as she was not presented as a witness. While alibi is a weak defense, conviction must be based on the strength of the prosecution’s evidence, not on the weakness of the defense. The prosecution’s evidence was insufficient to prove guilt beyond reasonable doubt.