GR 122510; (March, 2000) (Digest)
G.R. Nos. 122510-11; March 17, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. HERACLEO MANRIQUEZ y ALIA and GREGORIO CANOY y ZAMORA @ GREG, HERMINIA HERRERA @ HERMIE, BUTONG DAE, and PAT. PAULINO ROMARATE (at large), accused, GREGORIO CANOY, accused-appellant.
FACTS
Accused-appellant Gregorio Canoy, along with Heracleo Manriquez and others, was charged with two counts of murder for the deaths of Ernesto Gabuyan and Ferdinand Duay, both Metrodiscom Anti-Narcotics Unit agents, on 12 January 1990. The prosecution presented eyewitnesses who testified that Pat. Paulino Romarate, with Canoy and Manriquez, handcuffed and abducted the victims from a public area. A neighbor, Ramon de Asis, later saw Canoy and Manriquez with a dead body, and Romarate stated they killed a “sparrow.” The accused later surrendered, confessing their involvement to police and executing extra-judicial confessions detailing their participation under Romarate’s direction. The defense claimed they were merely present during a failed buy-bust operation and that Romarate alone was responsible for the killings.
ISSUE
The core issue is whether the extra-judicial confessions of the accused are admissible as evidence against them, given the constitutional rights of persons under custodial investigation.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the admissibility of the extra-judicial confessions. The legal logic centered on a valid waiver of the right to counsel. The arresting officers properly apprised Canoy and Manriquez of their constitutional rights. Crucially, they were assisted by a lawyer from the Public Attorney’s Office, Atty. Ridgeway Tanjili, before they executed their sworn statements. This assistance satisfied the requirement for counsel under Section 12, Article III of the Constitution and Republic Act No. 7438. The confessions were therefore voluntarily made with proper legal guidance. The Court found the confessions, corroborated by eyewitness testimony and physical evidence, sufficient to establish conspiracy and prove guilt beyond reasonable doubt for murder, qualified by treachery. However, applying the Indeterminate Sentence Law, the penalty was reduced from reclusion perpetua to an indeterminate penalty.