GR 127493; (December, 1999) (Digest)
G.R. No. 127493 December 8, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ORLANDO LABTAN y DAQUIHON, HENRY FELICIANO y LAGURA and JONELTO LABTAN, accused, HENRY FELICIANO y LAGURA, accused-appellant.
FACTS
Accused-appellant Henry Feliciano was charged with highway robbery under PD 532 and robbery with homicide under the Revised Penal Code. The charges stemmed from separate incidents involving the robbery of a jeepney driver and the robbery and killing of another driver. His co-accused remained at large. The prosecution’s case primarily relied on a sworn statement executed by Feliciano before the police, wherein he admitted participation in the crimes. During trial, Feliciano repudiated this statement, claiming it was extracted through force and intimidation without the assistance of counsel.
At trial, the defense presented Atty. Pepito Chavez, the lawyer who assisted during the custodial investigation. Atty. Chavez testified that he was merely asked to notarize the statement and did not explain Feliciano’s constitutional rights to him, nor did he provide meaningful legal advice. The prosecution presented no other evidence directly linking Feliciano to the crimes, such as eyewitness identification or corroborative testimony from the victims of the highway robbery.
ISSUE
Whether the extrajudicial confession of the accused-appellant is admissible as evidence to sustain his conviction.
RULING
The Supreme Court acquitted accused-appellant Henry Feliciano. The Court ruled that the extrajudicial confession was inadmissible as it was obtained in violation of his constitutional rights during custodial investigation. The testimony of Atty. Chavez established that the required procedural safeguards under Republic Act No. 7438 were not observed; the lawyer did not explain Feliciano’s rights or provide competent and independent counsel. A confession obtained without such valid waiver of rights is inadmissible in evidence.
With the confession excluded, the remaining evidence was insufficient to prove guilt beyond reasonable doubt. For the highway robbery charge, the victim’s initial police report did not identify Feliciano, creating reasonable doubt. For the robbery with homicide charge, there was a complete absence of any other evidence linking him to the crime. The prosecution failed to discharge its burden of proof. Consequently, the constitutional presumption of innocence prevails, mandating acquittal.