G.R. No. 78852 , June 5, 1989
The People of the Philippines, plaintiff-appellee, vs. Guillermo Eglipa, accused-appellant.

FACTS

Appellant Guillermo Eglipa was convicted of Murder by the Regional Trial Court of Bacoor, Cavite, for the killing of Ricardo Gardeleza, a minister of the Iglesia ni Kristo, on August 16, 1982. The conviction was based primarily on two extra-judicial confessions executed by Eglipa on August 17, 1982, at the Bacoor Police Station and on September 10, 1982, at the Criminal Investigation Service in Camp Crame. The prosecution’s eyewitness, Gerson Samson, was not credited by the trial court due to inconsistencies. The co-accused, Rudy Valiente, was acquitted.
The trial court admitted the confessions despite noting they were taken without the assistance of counsel. It considered the constitutional requirements on custodial investigation from the 1985 case of People vs. Galit as mere “governing guidelines” for future cases and held the confessions admissible because they were executed before the promulgation date (April 26, 1983) of the foundational case Morales vs. Ponce Enrile. On appeal, Eglipa challenged the admissibility of these confessions.

ISSUE

The sole issue is whether the extra-judicial confessions of the appellant are admissible as evidence against him.

RULING

The Supreme Court reversed the conviction and acquitted appellant Guillermo Eglipa. The Court ruled the confessions inadmissible. While the trial court correctly noted the confessions preceded the Morales doctrine, the Supreme Court, in other contemporaneous cases, had already declared confessions executed before April 26, 1983, inadmissible if taken in violation of constitutional rights. More critically, the Court found Eglipa successfully proved the confessions were involuntary, extracted through force, intimidation, and improper inducement.
The appellant’s testimony detailed how he was forced to sign the first confession at the Bacoor Police Station after being promised release, and how he was coerced into the second confession at Camp Crame after being struck and given promises regarding his detention. The Court emphasized that for a confession to be admissible, it must be free, voluntary, and made with the assistance of competent and independent counsel. The prosecution failed to rebut Eglipa’s specific allegations of coercion. With the confessions excluded, no other competent evidence remained to sustain the conviction. Consequently, the Court acquitted Eglipa on the ground of reasonable doubt.