G.R. No. 62805; January 22, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME BUENAFLOR y ARCILLA, accused-appellant.

FACTS

The accused-appellant, Jaime Buenaflor, was convicted of the complex crime of rape with homicide and sentenced to death by the Court of First Instance of Albay. The victim was ten-year-old Marites Barado, found dead and sexually assaulted in an isolated area on February 18, 1981. The prosecution’s case hinged primarily on Buenaflor’s extrajudicial confession. He was apprehended near the crime scene and, after interrogation, executed a sworn statement detailing how he raped and strangled the child. In this statement, he admitted to the acts and described his clothing, which was presented as evidence.
At trial, Buenaflor repudiated this confession. He testified that he was illiterate and had been coerced into affixing his thumbmark on the document after being physically assaulted by a policeman. He claimed the confession was not voluntary. The prosecution offered no other direct evidence, such as eyewitness testimony or forensic evidence conclusively linking Buenaflor to the crime, relying almost entirely on the disputed confession.

ISSUE

The central issue is whether the extrajudicial confession of the accused, obtained without the assistance of counsel and subsequently repudiated as coerced, is admissible and sufficient to sustain a conviction for rape with homicide beyond a reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Jaime Buenaflor. The legal logic rests on the constitutional right to counsel and the requirement of proof beyond reasonable doubt. The Court found the extrajudicial confession constitutionally infirm. While the investigating officer claimed to have informed Buenaflor of his rights, the waiver of the right to counsel was made orally and without the actual presence of a lawyer. For a waiver to be valid, especially for an illiterate individual, it must be made with the assistance of counsel. The absence of counsel during the waiver and the subsequent taking of the confession rendered it inadmissible as evidence.
With the confession excluded, the prosecution’s case collapsed. No other substantial evidence remained to prove Buenaflor’s guilt. The Court emphasized that the prosecution must rely on the strength of its own evidence, not on the weakness of the defense. The trial court’s reliance on the confession and its assessment of witness credibility were also flawed, as the convicting judge did not personally conduct the trial. Consequently, the guilt of the accused was not established to a moral certainty. The constitutional presumption of innocence prevailed, and Buenaflor was acquitted on the ground of reasonable doubt.