G.R. No. 118866 -68 September 17, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO DE LA CRUZ, alias RODOLFO DOMINGO or “OMPONG,” accused-appellant.

FACTS

Accused-appellant Rodolfo de la Cruz was convicted of three counts of murder for the deaths of Teodorico Laroya, Jr. and his two children. The victims were found stabbed to death in their home. The prosecution’s case heavily relied on an extrajudicial confession allegedly executed by appellant. Police officer SPO1 Carlos Atanacio, Jr. testified that before interrogation, appellant was fully informed of his constitutional rights in the presence of his counsel, Atty. Lorenza Bernardino-Villanueva, and subsequently signed a detailed confession.
Appellant, who has a speech impediment and limited education, presented a contrary version. He testified that he was never assisted by counsel during custodial investigation, did not meet the alleged lawyer, and was tortured into signing the confession. He admitted being at the victims’ residence on the night of the murder but denied committing the crimes, claiming he left them alive. The confession was written in fluent Tagalog, which appellant contended he could not have produced given his linguistic limitations.

ISSUE

The core issue is whether the extrajudicial confession was obtained in accordance with constitutional and statutory safeguards, rendering it admissible as evidence.

RULING

The Supreme Court reversed the conviction and acquitted appellant. The Court held the extrajudicial confession inadmissible for violating appellant’s constitutional rights during custodial investigation. Section 12(1), Article III of the Constitution mandates that a person under investigation must be informed of the right to remain silent and to have independent counsel, preferably of their own choice. Any waiver of these rights must be in writing and in the presence of counsel.
The Court found the prosecution failed to prove a valid waiver. SPO1 Atanacio admitted the investigation commenced while appellant was without counsel. The alleged assisting counsel, Atty. Villanueva, was neither presented in court nor shown to have been chosen by appellant, casting doubt on the legitimacy of the legal assistance. Furthermore, given appellant’s speech defect and limited schooling, a meaningful communication and understanding of his rights was not satisfactorily established. The confession, being the product of an investigation conducted without adherence to these strict procedural safeguards, is inadmissible under the Constitution. Without this confession, the remaining evidence was insufficient to establish guilt beyond reasonable doubt.