G.R. No. 93142 ; July 31, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDDIE FONTANILLA y COLOBAN, BOBBY SORIANO y APULINO, accused-appellants.

FACTS

Accused-appellants Eddie Fontanilla and Bobby Soriano, along with Ricardo Sibidal (at large), were charged with the murder of Federico Bangayan. The prosecution’s primary evidence consisted of the eyewitness testimony of the victim’s wife, Rosalinda Bangayan, and the extrajudicial confessions of Fontanilla and Soriano. Rosalinda testified that on the evening of November 21, 1985, Sibidal knocked on their door, and upon her husband opening it, Sibidal stabbed him, followed by Soriano and Fontanilla. The assailants then dragged her husband out. She later identified Fontanilla when the group returned to the area. However, during initial police investigation, she stated she did not know the perpetrators due to fear.
The trial court convicted all three accused of murder, sentencing them to reclusion perpetua. Fontanilla and Soriano appealed, arguing that their extrajudicial confessions were inadmissible and that the eyewitness identification was unreliable.

ISSUE

Whether the guilt of the accused-appellants was proven beyond reasonable doubt, considering the admissibility of their extrajudicial confessions and the credibility of the eyewitness testimony.

RULING

The Supreme Court reversed the conviction and acquitted the accused-appellants. The Court held that the extrajudicial confessions were inadmissible as they were obtained in violation of constitutional rights. For Fontanilla, the tape-recorded investigation failed to show he was informed of his right to remain silent and to counsel. For Soriano, while he was apprised of his rights, the waiver was not made voluntarily, knowingly, and intelligently in the presence of counsel. The hostile, police-dominated atmosphere vitiated the free will required for a valid waiver.
Regarding the eyewitness account, the Court found Rosalinda’s testimony insufficient to sustain a conviction. Her initial statement to police that she could not identify the killers due to fear created reasonable doubt about her subsequent courtroom identification. The positive identification of Fontanilla was also weakened by her admission that she only saw him when the group returned, and he was wearing a hat. The prosecution failed to prove guilt beyond reasonable doubt. The constitutional right against self-incrimination and to counsel must be strictly observed, and any evidence obtained in violation thereof is inadmissible.