GR 62305; (November, 1992) (Digest)
G.R. No. 62305 November 23, 1992
ANGEL SAMPAGA Y DELOS REYES, petitioner, vs. PEOPLE OF THE PHILIPPINES AND THE COURT OF APPEALS, respondents.
FACTS
Angel Sampaga y de los Reyes was charged with Homicide for stabbing his cousin, Marciano Soria y Posedia, on April 7, 1976, in Quezon City. The incident occurred after a drinking spree at Sampaga’s residence, where they had a heated argument. Witnesses left the scene before the stabbing. The victim died from the stab wound. During police investigation, Sampaga was informed of his constitutional rights to remain silent and to counsel. He executed a sworn extra-judicial confession admitting the killing and revealed the location of the weapon, which he subsequently surrendered. The prosecution’s case relied primarily on this extra-judicial confession, as the other witnesses were not presented at trial. Sampaga invoked self-defense in his statement but refused to present evidence in his defense during trial. The trial court found him guilty of Homicide, which the Court of Appeals affirmed.
ISSUE
Whether the extra-judicial confession of the accused, obtained during custodial investigation without the assistance of counsel, is admissible in evidence.
RULING
No. The Supreme Court acquitted the petitioner. The extra-judicial confession was obtained in violation of Section 20, Article IV of the 1973 Constitution, which guarantees the right to remain silent and to counsel during investigation. Although the accused was informed of these rights, he was not provided with counsel nor given an opportunity to secure one. Following the doctrine in People vs. Jimenez, any confession or admission obtained during custodial investigation without the assistance of counsel is inadmissible in evidence, even if voluntarily made or later corroborated by external circumstances. The act of revealing and surrendering the weapon was considered part of the custodial interrogation and thus also inadmissible. In the absence of independent evidence apart from the inadmissible confession, the prosecution failed to prove guilt beyond reasonable doubt.