G.R. No. L-64848 August 11, 1988
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO ELEGINO y SORRONTO, RODOLFO BUENBRAZO y BASTASA, and ULDARICO SANCHEZ y TUPAZ, accused.

FACTS

Accused Eduardo Elegino, Rodolfo Buenbrazo, and Uldarico Sanchez were charged with Robbery with Homicide for the killing of taxi driver Eliseo Gamonido and the taking of P70.00 on September 14, 1980. The prosecution’s case relied heavily on the extrajudicial confessions of the accused and the testimony of Uldarico Sanchez, who was discharged to become a state witness. Sanchez testified that after a day of drinking, the trio hired the victim’s taxi. An altercation ensued between Buenbrazo and the driver, leading Buenbrazo to choke and strangle Gamonido. Sanchez claimed he was surprised and yelled for Buenbrazo to stop. After the driver was killed, they drove the taxi to a beach. Sanchez stated that Elegino took the victim’s wallet and handed it to Buenbrazo, who removed the money. The trial court convicted Elegino and Buenbrazo, sentencing them to death.

ISSUE

The primary issue was whether the extrajudicial confession of accused Eduardo Elegino was admissible as evidence against him, given constitutional safeguards.

RULING

The Supreme Court reversed Elegino’s conviction and ordered his acquittal. The legal logic centered on the inadmissibility of his extrajudicial confession. The Court emphasized that under the 1973 Constitution, a person under investigation must be informed of their right to remain silent and to counsel, and that no force or intimidation vitiating free will shall be used. While a lawyer, Atty. Teofilo Gamad, signed as a witness to the confession, Elegino denied seeing any lawyer during his investigation. Critically, the prosecution failed to present Atty. Gamad as a witness to affirm that Elegino was properly assisted and that his confession was voluntary. This failure rendered the confession inadmissible. Without this confession, the only evidence against Elegino was Sanchez’s testimony that he saw Elegino hold the wallet before Buenbrazo took it. This was insufficient to prove Elegino’s direct participation in the robbery or homicide, as the testimony indicated Buenbrazo took the money and the wallet was later recovered. Consequently, the evidence failed to establish Elegino’s guilt beyond reasonable doubt. Regarding Buenbrazo, who withdrew his appeal, his conviction was affirmed but the death penalty was commuted to reclusion perpetua in accordance with the 1987 Constitution .