GR 130189; (June, 1999) (Digest)
G.R. No. 130189 June 25, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOMINGO R. MULETA, accused-appellant.
FACTS
The prosecution’s case rested primarily on an extra-judicial confession and circumstantial evidence. Accused-appellant Domingo Muleta was charged with the complex crime of rape with homicide for the death of his niece, Charito Delgado, whose body was found in Malolos, Bulacan. The National Bureau of Investigation (NBI) agent testified that Muleta, during custodial investigation assisted by counsel Atty. Deborah Daquis, confessed to the crime. A witness, Danilo Delgado, also testified that during the victim’s wake, Muleta became hysterical, uttered words seeking forgiveness, and ingested bleach.
The defense presented a denial and alibi. Muleta claimed he was tortured by the NBI into signing a prepared confession and that the lawyer assigned to assist him, Atty. Daquis, was not of his own choosing and did not provide meaningful assistance. He asserted he was elsewhere at the time of the crime and had actively reported the victim’s disappearance to various police stations.
ISSUE
The core issue is whether the extra-judicial confession was admissible and whether the remaining evidence sufficed to prove Muleta’s guilt beyond reasonable doubt.
RULING
The Supreme Court ACQUITTED Domingo Muleta. The extra-judicial confession was ruled inadmissible. The Court found the waiver of rights and the assistance of counsel during custodial investigation were constitutionally infirm. Atty. Daquis was not shown to be a competent and independent counsel chosen by the accused; her presence was a mere ceremonial formality. A valid waiver requires the assistance of counsel, and where the counsel’s assistance is not genuine, the waiver is void. Consequently, the confession, being the product of this violation, was excluded as evidence.
With the confession excluded, the remaining circumstantial evidence was insufficient to sustain a conviction. The alleged hysterical utterances at the wake were ambiguous and did not constitute a clear admission of guilt. The prosecution failed to establish an unbroken chain of circumstances leading to the sole and inescapable conclusion that Muleta was the perpetrator. A conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. Since the admissible evidence did not prove guilt beyond reasonable doubt, the accused was entitled to an acquittal.