G.R. No. 153119 ; April 13, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ANTONIO REYES y MAGANO, appellant.

FACTS

On June 11, 1998, in Lumban, Laguna, Dr. Aurora Lagrada was found dead in her home. Responding barangay officials and police discovered her bloodied body near a bolo. Her neighbor, appellant Antonio Reyes, was absent from the scene. Information led police to locate and arrest Reyes in a nearby town plaza. Upon frisking him, authorities recovered items belonging to the victim, including a Rolex watch, a gold bracelet, a ring, her bank passbook, and cash. At the police station, Reyes, bothered by his conscience, expressed a desire to confess. Investigator SPO2 Benedicto del Mundo informed him of his rights and, upon Reyes’s request for a lawyer, procured Atty. Wilfredo Paraiso. Atty. Paraiso thoroughly explained the appellant’s constitutional rights, and Reyes affirmed his voluntary decision to confess without coercion or promise of reward.
The appellant executed a detailed extrajudicial confession admitting to the crime. He stated that he entered the victim’s house with intent to rob, was discovered, and in the ensuing struggle, stabbed her with a bolo before taking her valuables. The prosecution presented this confession alongside the seized items and testimonies of the arresting officers and the assisting counsel. The defense presented a different version, claiming the confession was coerced and that he was merely a witness to the crime committed by another. The Regional Trial Court convicted appellant of robbery with homicide and imposed the death penalty.

ISSUE

The core issue is whether the extrajudicial confession of the appellant is admissible as evidence to sustain his conviction for robbery with homicide.

RULING

The Supreme Court affirmed the conviction but modified the penalty to reclusion perpetua. The Court upheld the admissibility of the appellant’s extrajudicial confession. The legal logic rests on strict compliance with constitutional safeguards. The record clearly shows the appellant was informed of his right to remain silent and to counsel. Critically, when he requested a lawyer, the police secured Atty. Paraiso, a competent and independent counsel. Atty. Paraiso did not act as a mere passive witness but actively counseled the appellant, explaining the consequences of confessing and ensuring the waiver of rights was knowing, intelligent, and voluntary. The appellant affirmed he was not coerced. This procedure satisfied the requirements for a valid waiver.
The confession was also corroborated by evidence of corpus delicti—the fact of the robbery and homicide was established by the discovery of the victim’s body and the missing properties. The stolen items were found in the appellant’s possession shortly after the crime. His flight and attempt to leave town further indicated guilt. The defense of frame-up was deemed unconvincing. However, due to the passage of Republic Act No. 9346 prohibiting the death penalty, the Supreme Court modified the sentence to reclusion perpetua and awarded exemplary damages to the victim’s heirs.