Facts: The accused-appellants were convicted of rape and homicide. The prosecution was based solely on the alleged extrajudicial confessions taken by the police officers without the presence of a counsel during custodial investigation. It was also notable that the prosecution did not present any witness to the actual commission of the crime and the basis of the lower court’s conviction to the accused was based on their alleged extrajudicial confessions.
Issue: Whether or not the lower court erred in convicting the appellants based on their extrajudicial confession.
Held: The court held that under rules laid down by the Constitution and existing law and jurisprudence, a confession to be admissible must satisfy all of four fundamental requirements: 1) the confession must be voluntary 2) the confession must be made with the assistance of competent and independent counsel; 3) the confession must be express and 4) the confession must be in writing.
The court noted that the assistance of a counsel provided for the accused was inadequate to meet the standard requirements of the constitution for custodial investigation. It seems that the lawyers were not around throughout the custodial investigation. Citing People vs Javar, the court reiterated that any statement obtained in violation of the constitutional provision, or in part, shall be inadmissible in evidence. “Even if the confession speaks the truth, if it was made without the assistance of counsel, it becomes inadmissible in evidence regardless of the absence of coercion or even if it had been voluntarily given.” Thus, because of these defects in observing the proper procedural requirements of the constitution on custodial investigation the accused-appellants were acquitted.
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