G.R. No. 80179 March 19, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REY MANLAPAZ y MANDO, CESAR MURCIA y MAGPUSAO, RENATO SANTOS y APILANES, defendants, CESAR MURCIA y MAGPUSAO, defendant-appellant.

FACTS

The accused, including appellant Cesar Murcia, were charged with Robbery with Homicide for the death of Teodoro Tan on September 13, 1981. The trial court convicted all three and sentenced them to reclusion perpetua. During appeal, co-accused Manlapaz escaped, leading to the dismissal of his appeal, while Santos withdrew his. Only Murcia’s appeal proceeded. The prosecution’s case relied heavily on extrajudicial confessions. Police, acting on underworld information, arrested the three accused at Manlapaz’s residence. Murcia, in a sworn statement, admitted being part of a group that assaulted the victim, with the intent to rob, and receiving a share of the stolen money.
At trial, Murcia repudiated his confession, claiming it was extracted through force and intimidation. He testified that he was mauled by police inside a jeepney, hitting his chest, abdomen, back, and head, and was threatened with further harm if he did not sign the prepared statement. The defense argued the confession was inadmissible as it was obtained without the assistance of counsel during custodial investigation, in violation of constitutional rights.

ISSUE

Whether the extrajudicial confession of appellant Cesar Murcia is admissible as evidence to sustain his conviction for Robbery with Homicide.

RULING

No. The Supreme Court acquitted appellant Cesar Murcia. The ruling hinged on the inadmissibility of his extrajudicial confession due to a violation of his constitutional rights during custodial investigation. The Court emphasized that the 1973 Constitution, applicable at the time, explicitly guaranteed the right to remain silent and to counsel, rendering any confession obtained without such counsel inadmissible. Leading jurisprudence established that no custodial investigation should proceed unless conducted with the presence of counsel engaged by the arrested person or appointed by the court.
The Court found that Murcia’s confession, the primary evidence against him, failed to meet this constitutional standard. His testimony regarding police maltreatment and the absence of counsel during the taking of his statement rendered the confession invalid. Without this confession, the remaining evidence was insufficient to prove guilt beyond reasonable doubt. Testimonies regarding the recovery of the victim’s shoes implicated only co-accused Manlapaz, not Murcia. Furthermore, any finding of conspiracy by the trial court could not stand once the confessions were excluded. The testimony of Manlapaz against Murcia was also correctly disregarded as hearsay. Consequently, with the prosecution’s case resting on an inadmissible confession and no other conclusive evidence linking Murcia to the crime, the Court was compelled to acquit him based on reasonable doubt. The judgment of conviction was set aside.