G.R. No. L-65189 May 28, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE O. DUHAN, MANUEL RECLA and ROGER REYES, accused-appellants.

FACTS

The accused-appellants were convicted by the Regional Trial Court of Manila for selling dried marijuana leaves and a marijuana cigarette in violation of the Dangerous Drugs Act. The prosecution’s narrative, as accepted by the trial court, detailed a buy-bust operation on June 29, 1982. A confidential informer, using marked money, purchased the drugs from the appellants at a designated area while police operatives observed from a distance. Upon consummation of the sale, the appellants were arrested. The marked money was allegedly recovered from Duhan, and a marijuana cigarette was found in Reyes’s wallet. The seized items tested positive for marijuana. The appellants, however, presented a starkly different version. They claimed they were indiscriminately rounded up during a police saturation drive, manhandled, and that the drugs were planted on them. They alleged they were forced to admit guilt at the police station after being subjected to maltreatment.

ISSUE

The core issue is whether the prosecution proved the guilt of the appellants beyond reasonable doubt, particularly in light of the conflicting narratives and the admissibility of the alleged admissions made during custodial investigation.

RULING

The Supreme Court reversed the conviction and acquitted the appellants. The Court found the evidence for the prosecution insufficient to meet the required quantum of proof beyond reasonable doubt. A critical flaw was the prosecution’s reliance on the appellants’ alleged admissions during custodial investigation, as reflected in the Booking and Information Sheets stating they “readily admitted guilt.” The Court emphasized the constitutional duty of law enforcers, under Section 20, Article IV of the 1973 Constitution, to inform a person under investigation of their right to remain silent and to counsel. This duty is not perfunctory; it requires an effective explanation of these rights in practical terms and in a language understood by the subject, considering their education and intelligence. The prosecution failed to affirmatively demonstrate that this duty was complied with. There was no showing that the appellants, who were of limited education, were given an adequate explanation of their rights or were assisted by counsel. Consequently, these alleged admissions were inadmissible as evidence. With this crucial evidence excluded, the remaining proof was rendered inadequate to sustain a conviction. The conflicting accounts created reasonable doubt, which must be resolved in favor of the accused.