GR 247718; (March, 2021) (Digest)
G.R. No. 247718 , March 03, 2021
People of the Philippines, Plaintiff-Appellee, vs. Jaynard Agustin y Paraggua, Accused-Appellant.
FACTS
Accused-appellant Jaynard Agustin y Paraggua was charged with Rape with Homicide for allegedly raping and killing AAA, a 12-year-old minor, on November 1, 2010, in Cagayan. The prosecution presented witnesses, including the medico-legal officer, Dr. Francisco Romulo D. Villaflor, who testified that AAA died from asphyxia by strangulation and had genital injuries consistent with forceful sexual intercourse. A key piece of evidence was Agustin’s extrajudicial confession, taken on November 2, 2010, with the assistance of Atty. Luis Donato, Jr., wherein he admitted to raping and killing AAA. Agustin, during trial, denied the charges, claimed he did not know Atty. Donato, Jr., and denied placing his thumbprint on the confession. The Regional Trial Court (RTC) found him guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and ordered him to pay damages. The Court of Appeals affirmed the RTC decision with modifications. Agustin appealed to the Supreme Court.
ISSUE
Whether the extrajudicial confession of accused-appellant Jaynard Agustin y Paraggua is admissible and sufficient to sustain his conviction for the crime of Rape with Homicide.
RULING
The Supreme Court GRANTED the appeal, REVERSED and SET ASIDE the Decision of the Court of Appeals, and ACQUITTED accused-appellant Jaynard Agustin y Paraggua on the ground of reasonable doubt. The Court ordered his immediate release from detention unless held for another lawful cause.
The Court held that the extrajudicial confession was inadmissible as evidence. The confession document was written in English, a language not known to Agustin, who was unschooled and only conversant in Ilocano. While Atty. Donato, Jr. claimed to have translated the questions and answers, the document itself did not reflect this process, nor did it contain a certification by the investigating officer that the confession was read and translated to Agustin in a language he understood, as required by law ( Republic Act No. 7438 ). The confession was therefore obtained in violation of Agustin’s constitutional rights. Without the confession, the remaining circumstantial evidence was insufficient to prove his guilt beyond reasonable doubt. The medico-legal findings, while establishing the crime of rape with homicide, did not point to Agustin as the perpetrator. The prosecution failed to present any other evidence, such as eyewitness testimony or physical evidence, linking Agustin to the crime. Consequently, his guilt was not established with moral certainty, warranting acquittal.