GR 52016; (May, 1981) (Digest)
G.R. No. L-52016 May 13, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEVERINO DUERO, Accused.
FACTS
Fausta Condino Vda. de Duero, an elderly woman living alone, was found brutally murdered in her home in Cabatuan, Iloilo, on October 25, 1976. She had suffered multiple fatal wounds, including a scythe stuck in her neck and a wire used for strangulation. Investigation revealed that money and jewelry were missing from her house, establishing the corpus delicti of robbery with homicide. No eyewitness to the crime was presented.
The prosecution’s case hinged primarily on the accused Severino Duero’s alleged oral confession. Police officers testified that Duero voluntarily confessed his involvement to the police station commander and other officers, both at the station and while in transit. He reportedly admitted to killing the victim after she refused to lend him money, and he implicated others who were later cleared. The accused, however, repudiated this confession when he testified in court.
ISSUE
Whether the trial court erred in convicting the accused of robbery with homicide based on his oral confession taken during custodial interrogation without the required constitutional warnings.
RULING
Yes. The Supreme Court reversed the conviction and acquitted the accused. The Court applied the constitutional safeguards under Section 20, Article IV of the 1973 Constitution, which mandates that any person under investigation for the commission of an offense must be informed of his right to remain silent and to have competent and independent counsel, preferably of his own choice. These rights cannot be waived except in writing and in the presence of counsel.
The Court, citing Miranda v. Arizona, ruled that the prosecution carries a heavy burden to demonstrate a knowing and intelligent waiver of these rights before any custodial confession can be admissible. The procedural safeguards require that a suspect be warned of his rights to silence and counsel prior to any questioning, and an opportunity to exercise these rights must be afforded throughout the interrogation. The record showed that the police did not inform Duero of his constitutional rights before taking his oral confession. Consequently, this confession was inadmissible as evidence. Without this inadmissible confession, the remaining circumstantial evidence presented by the prosecution was insufficient to prove Duero’s guilt beyond a reasonable doubt. The death penalty was set aside.