GR 117397; (November, 1996) (Digest)
G.R. No. 117397 November 13, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERMELINDO SEQUIÑO, VICENTE TUMANGAN, and NENITO MELVIDA, accused-appellants.
FACTS
On April 24, 1991, Eugenio Godinez and Pedro Broniola, employees of Hacienda Jose Ancajas, withdrew the payroll money from Medellin Rural Bank. Driven by bank driver Jimmy Serafin on a motorcycle, they were waylaid in Sitio Lahug by three armed men. Godinez recognized the assailants as former co-workers Sequiño and Melvida, and neighbor Tumangan. As Serafin accelerated to escape, a gunshot was heard, causing Broniola to fall. The motorcycle then fell, pinning Godinez. Accused Tumangan approached, took the money bag from Godinez, and fled with his companions. Broniola died from a gunshot wound to the head.
The police, led by SPO Elpidio Luna, responded. At the scene, they found a bio-data sheet bearing Nenito Melvida’s name. Luna located and brought Melvida in for investigation. Without counsel present, Melvida admitted participation, named Sequiño and Tumangan as accomplices, and led police to his house where he surrendered P9,000 of the loot. This extrajudicial admission and the recovered money were used against all three accused.
ISSUE
Whether the guilt of accused-appellants for the crime of Robbery with Homicide was proven beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED accused-appellants. The prosecution failed to establish their guilt beyond reasonable doubt. The core of the case rested on the uncounseled extrajudicial confession of Nenito Melvida and the money recovered from him. The Court ruled that Melvida’s confession, obtained during custodial investigation without the assistance of competent and independent counsel, is inadmissible in evidence against him under Section 12(1), Article III of the Constitution . Furthermore, such a confession is not admissible against his co-accused, Sequiño and Tumangan, as it is considered hearsay against them. The recovery of the P9,000 was a direct fruit of this illegal confession; therefore, it is also inadmissible as evidence under the “fruit of the poisonous tree” doctrine. Without these pieces of evidence, the remaining identification by eyewitness Godinez was deemed insufficient to sustain a conviction. The Court found his testimony lacked the requisite certainty, as he failed to categorically identify the appellants during the trial. Consequently, the constitutional presumption of innocence prevailed.