GR 145176; (March, 2004) (Digest)
G.R. No. 145176; March 30, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. SANTIAGO PERALTA y POLIDARIO (at large), ARMANDO DATUIN JR. y GRANADOS (at large), ULYSSES GARCIA y TUPAS, MIGUELITO DE LEON y LUCIANO, LIBRANDO FLORES y CRUZ and ANTONIO LOYOLA y SALISI, accused, ULYSSES GARCIA y TUPAS, MIGUELITO DE LEON y LUCIANO, LIBRANDO FLORES y CRUZ and ANTONIO LOYOLA y SALISI, appellants.
FACTS
The appellants, along with two others at large, were convicted by the Regional Trial Court of qualified theft for stealing P194,190.00 in punctured currency notes due for shredding from the Central Bank (now Bangko Sentral ng Pilipinas). The prosecution’s case heavily relied on the extra-judicial confessions of appellant Ulysses Garcia, given over three days while in police custody. Garcia implicated himself and his co-accused. At trial, Garcia recanted, claiming his confessions were extracted through torture—he was allegedly blindfolded, handcuffed, beaten, and threatened with “salvaging.” The other appellants denied involvement, asserting their confessions were also coerced. The trial court rejected these claims, noting the lack of medical evidence or complaints against the officers, and found the confessions to be voluntary.
ISSUE
The core issue is whether the extra-judicial confessions of the appellants, particularly that of Ulysses Garcia, were voluntarily executed and admissible as evidence against them and their co-accused.
RULING
The Supreme Court ACQUITTED appellants Ulysses Garcia, Miguelito de Leon, Librando Flores, and Antonio Loyola. The Court ruled that Garcia’s confessions were inadmissible. The legal logic centered on the right to counsel under Section 12(1), Article III of the Constitution. The Court found that the assisting lawyer, Atty. Jose Hernandez-Dy, failed to provide the effective and vigilant representation required by law. The records showed the lawyer merely witnessed the signing without conducting a meaningful consultation; he did not inquire into the circumstances of Garcia’s arrest or the alleged torture, nor did he ensure Garcia understood his rights and the consequences of his confession. A lawyer’s role cannot be reduced to a passive witness. Consequently, the confessions were obtained in violation of constitutional rights and were excluded as “fruit of the poisonous tree.”
Without these inadmissible confessions, the remaining evidence against all appellants was insufficient to prove guilt beyond reasonable doubt. Garcia’s possession of three punctured bills was inconclusive, and the evidence against the others, largely based on Garcia’s uncorroborated statements, collapsed. The flight of the two co-accused could not shore up the case. The prosecution failed to discharge its burden of proof, necessitating acquittal.