G.R. No. 117202 ; February 13, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DEORITO PORIO y RAPSING, accused-appellant.

FACTS

On June 25, 1990, the lifeless body of 11-year-old Riza Cleodoro Flores was found near a creek in Olongapo City. The autopsy report concluded the cause of death was neurogenic shock and asphyxia by strangulation. Genital findings were compatible with sexual intercourse with a man, accompanied by violence. The victim’s mother informed barangay officials that the accused, Deorito Porio, had attempted to rape her daughter on three prior occasions.
The day after the body was discovered, Porio was brought to the police station. He initially admitted to the crime orally. The following day, he was formally informed of his constitutional rights by Pfc. Roosevelt Menor. As Porio could not name a lawyer, Atty. Juanito Atienza was provided to assist him. After conferring with Porio and explaining the gravity of the crime and his rights, Atty. Atienza witnessed Porio sign a waiver and a sworn confession detailing how he raped and strangled the victim.

ISSUE

The core issue is whether the extrajudicial confession of the accused is admissible as evidence against him.

RULING

The Supreme Court affirmed the conviction, holding the confession admissible and sufficient to establish guilt beyond reasonable doubt. The legal logic rests on strict compliance with constitutional safeguards for custodial investigations. The Court meticulously examined the process: Pfc. Menor informed Porio of his rights to remain silent and to counsel in a language he understood. When Porio could not secure a lawyer, the state provided Atty. Atienza. The lawyer did not merely act as a passive witness; he conferred with Porio, explained his rights anew, and advised him of the confession’s consequences. This ensured the waiver of rights was knowing, intelligent, and voluntary.
The confession itself is detailed, spontaneous, and contains facts only the perpetrator would know, corroborated by the medico-legal report. It is evidence of the highest order, as the presumption is that no sane person confesses to a grave crime without being prompted by truth and conscience. The defense of denial and alibi, uncorroborated and weak, cannot prevail over this positive, credible confession. The Court found no evidence that the confession was extracted through force, intimidation, or promise of reward. Therefore, having been obtained in accordance with law, it constitutes conclusive proof of Porio’s guilt for the complex crime of rape with homicide.