GR 117166; (December, 1998) (Digest)
G.R. No. 117166 , December 3, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RANDY MANTES, JEROME GARCIA, JOVY VELASCO, and DOMINGO FRANCISCO, accused-appellants.
FACTS
Accused-appellant Domingo Francisco was charged with Parricide, while his co-accused Randy Mantes, Jerome Garcia, and Jovy Velasco were charged with Murder for the death of Erliste Arcilla Francisco, Domingo’s wife. The prosecution’s case rested primarily on the testimonies of police officers who apprehended the accused. The officers testified that Domingo Francisco, after being brought to the station by the victim’s relatives, admitted his guilt and implicated his co-accused, who were allegedly relatives of his paramour. The co-accused also purportedly admitted their participation to the police. These alleged confessions were not reduced to writing. The burnt female cadaver was identified by the victim’s mother. The defense presented alibis and denied the accusations.
ISSUE
Whether the guilt of the accused-appellants was proven beyond reasonable doubt.
RULING
The Supreme Court reversed the trial court’s decision and acquitted all accused-appellants. The prosecution failed to establish their guilt beyond reasonable doubt. The alleged extrajudicial confessions, which were the cornerstone of the prosecution’s case, were inadmissible. The confessions were not in writing, signed, or sworn to before any official. Crucially, the accused were not assisted by counsel during the custodial investigation, a clear violation of their constitutional rights. The Court emphasized that uncounselled confessions are presumed involuntary and inadmissible as evidence. Furthermore, the alleged oral confession of Domingo Francisco to a neighbor was deemed unreliable due to the witness’s doubtful credibility and the accused’s denial. The existence of motive alone cannot substitute for proof beyond reasonable doubt. With the inadmissible confessions excluded, the remaining evidence was insufficient to sustain a conviction. The presumption of innocence prevailed.