GR 95028; (May, 1995) (Digest)
G.R. No. 95028 . May 15, 1995. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARLO COMPIL Y LITABAN, accused-appellant.
FACTS
Accused-appellant Marlo Compil was charged with robbery with homicide. The prosecution evidence established that on October 23, 1987, robbers entered MJ Furnitures in Manila, which also served as the residence of owners Manuel and Mary Jay. The intruders tied up Mary Jay and the maids, stole cash and jewelry, and stabbed Manuel Jay to death. Investigation led police to suspect Compil and his co-workers. On October 27, 1987, police, accompanied by a witness, located Compil in Tayabas, Quezon. Upon being identified, Compil was arrested. He allegedly confessed orally to his role as a lookout and later executed a sworn statement on October 28, 1987, with the assistance of a CLAO lawyer and in the presence of relatives.
After the prosecution rested, Compil filed a demurrer to evidence, which the trial court denied. The court admitted his extrajudicial confession, found him guilty, and sentenced him to reclusion perpetua. On appeal, Compil argued his confession was inadmissible as it was allegedly extracted without counsel during his initial arrest and interrogation.
ISSUE
Whether the extrajudicial confession of the accused-appellant is admissible as evidence against him.
RULING
The Supreme Court affirmed the conviction and held the confession admissible. The legal logic proceeds from a clear distinction between custodial investigation and general questioning. The constitutional right to counsel attaches only during custodial investigation, which begins when a person is taken into custody and is subjected to interrogation that tends to be incriminating. The Court found that Compil’s initial oral admissions at the time of his arrest in Tayabas were not the product of a formal custodial interrogation but were spontaneous statements made upon being confronted by the police and identified by a witness. The subsequent sworn statement, executed the following day in Manila, was conclusively shown to have been made with the assistance of counsel de parte, Melencio Claroz, and in the presence of his relatives. This formal confession complied with all legal requisites for admissibility.
The Court further ruled that, even disregarding the confession, the prosecution’s circumstantial evidence—including his presence with the conspirators before and after the crime, his flight, and the corroborative testimony of Pablo Pakit—adequately proved conspiracy. In conspiracy, the act of one is the act of all; thus, Compil, as a conspirator, was equally liable for the robbery with homicide. His defense of being a mere accomplice was rejected. The penalty of reclusion perpetua and the awarded damages were affirmed.