G.R. No. L-18179; June 29, 1962
LANDAWI PARASAN BILAAN, ET AL., petitioners, vs. VICENTE N. CUSI, ETC., respondents.

FACTS

Petitioners Landawi Parasan, Antik Felix, and Eris Seroc, all Bilaans who spoke no English, Spanish, Tagalog, or Visayan, were charged with robbery with multiple homicide before the Court of First Instance of Davao. The court experienced difficulty securing an interpreter for the Bilaan dialect. Consequently, the arraignment and the prosecution’s presentation of evidence, which included affidavits or confessions allegedly made by the accused admitting guilt, proceeded without one. The accused were initially represented by counsel de officio who, not knowing the Bilaan dialect, objected to the confessions only on the ground of lack of proper identification.
An interpreter, Atty. Primo S. Ocampo, who understood and spoke Bilaan, was finally secured on November 4, 1960, after the prosecution had rested. Upon conferring with the accused, Atty. Ocampo learned for the first time that the confessions were allegedly involuntary, extracted through beatings by police and constabulary personnel. When he attempted to present a witness to prove this coercion, the fiscal objected on the technical ground that the defense had made no prior reservation to dispute the voluntariness of the confessions. The trial court sustained the objection, barring the presentation of such evidence.

ISSUE

Whether the trial court committed a grave abuse of discretion in barring the newly-appointed counsel from presenting evidence to prove the alleged involuntariness of the accused’s confessions.

RULING

Yes. The Supreme Court granted the petition for certiorari, set aside the trial court’s order, and remanded the case for further proceedings. The legal logic centers on the fundamental right to a fair trial and the proper administration of justice, particularly for indigent and non-literate accused. The Court emphasized that during the critical stage when the prosecution presented its evidence, including the confessions, the petitioners were deprived of a crucial safeguard: an interpreter. Their initial counsel, who did not know their dialect, could not have adequately communicated with them to ascertain the circumstances under which the confessions were made. Therefore, any failure to make a prior reservation to challenge voluntariness was not a knowing or strategic waiver but a result of this fundamental deprivation.
When Atty. Ocampo, equipped with the necessary linguistic ability, assumed representation and discovered the claim of coercion, it became his duty to present evidence on the matter. To bar such evidence on a purely technical procedural objection, under these specific circumstances, would sanction a grave injustice. The Court held that fairness and substantive justice demand that the accused be given a full opportunity to prove the alleged involuntariness of the confessions, a matter going to the very heart of due process. The prosecution would suffer no prejudice, as it retains the right to rebut any evidence presented on the issue. The ruling prioritizes the substantive rights of the accused over rigid procedural technicalities when such technicalities would defeat the ends of justice.