G.R. No. L-63861 August 19, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SABAS POYOS alias Boy, LILIOSA POYOS alias Lily and FLORENCIO POYOS alias Lor, accused, FLORENCIO POYOS alias LOR, accused-appellant.

FACTS

Accused-appellant Florencio Poyos, along with Sabas and Liliosa Poyos, was charged with the murder of Paula Angoy in Balilihan, Bohol. Only Florencio was arraigned and tried after his co-accused escaped. The prosecution’s case hinged primarily on an extrajudicial confession signed by Florencio before a clerk of court, wherein he admitted to hitting the victim on the nape with a piece of wood for a monetary reward. The trial court found him guilty and imposed the death penalty, relying heavily on this confession.
At trial, Florencio repudiated his confession. He testified that he found the victim already dead upon arrival, having been told she died from an accidental fall. He merely assisted in moving the body and cleaning the scene. He claimed he signed a pre-prepared confession out of fear after police threatened to make “mamon” out of him, and that he was illiterate, only able to write his name. He also asserted that the stated amount of over P4,000.00 as payment was false, and that he had only received around P700.00 from Sabas for various services.

ISSUE

Whether the extrajudicial confession of the accused-appellant is admissible in evidence, considering his allegations of coercion and illiteracy, and whether the prosecution proved his guilt beyond reasonable doubt based on the remaining evidence.

RULING

The Supreme Court reversed the conviction and acquitted Florencio Poyos. The Court held that the extrajudicial confession was inadmissible and insufficient to sustain a conviction. Applying Article IV, Section 20 of the 1973 Constitution, which mandates that any confession obtained through force, intimidation, or without a valid waiver of the right to counsel and to remain silent is inadmissible, the Court found the confession void. The accused’s illiteracy and claim of police threat, coupled with the lack of counsel during custodial investigation, rendered the confession involuntary and unreliable. The subscribing officer’s verification was deemed insufficient to cure this constitutional defect.
With the confession excluded, the prosecution’s case collapsed. No other credible evidence directly linked Florencio to the crime. The autopsy report only established the cause of death but not the identity of the perpetrator. His conduct after the incident—staying in town and attending the wake instead of fleeing—was inconsistent with guilt. The Court emphasized that a conviction must rest on the prosecution’s strength, not the defense’s weakness. Since the sole basis for conviction was an invalid confession, and the prosecution failed to prove guilt beyond reasonable doubt, acquittal was imperative. The decision underscores the Court’s duty to protect the rights of the accused, especially those who are uneducated and vulnerable during custodial investigation.