People V Parel

Facts:

Accused-appellant was charged of the special complex crime of robbery with

murder before the RTC of Manila. The victim of the case was Leticia Perez, the
owner of Le Mars Restaurant and the step sister of his common law wife,
Estrellita San Luis.
On March 4, 1992, Letica called her son to help out at their restaurant as
Leticias step sisters were out and they were short staffed on that day.
Accused was then seen by several of the members lingering in the restaurant
talking to people and helping out in the kitchen while he waited for his wife to
come back. Some of the staff members noted the strange behavior of the
accused.
Leticia was later found dead due to asphyxiation/strangulation at around
eight o clock in the evening.
On March 6, 1992, appellant was held for questioning and allegedly admitted
to having strangled the deceased and divested her of Php 6,000 as he
needed the money for his trip with Estrellita to Bacolod. Appellant
vehemently denied the charges and claimed the money was given by his
brother Danilo.
Appellant also testified that the police who questioned him made him sign his
name and have his fingers printed on blank sheets of paper. When the
appellant refused, he was hit and maltreated. The following day, 7 March
1992, Sgt. dela Rosa directed him to sign the Booking Sheet and Arrest
Report and when he refused he was again maltreated.
On March 5, while appellant was being questioned by Sgt. Frajedas, Estrellita
arrived with a lawyer and the questioning was stopped but appellant
remained in detention. The following day, the officers from the WPD homicide
section continued the investigation and it was in the course thereof that said
admission was made.

RTC:

Appellant is guilty beyond reasonable doubt

CA:

No Mention.

Issue:
WON the circumstantial evidence now on record constitutes an unbroken
chain sufficient to convict the accused
Ruling:
The alleged extrajudicial admission of appellant that he was the one who
robbed and killed the deceased cannot be used as evidence against him.
The failure of the police investigators to inform appellant of his right to
remain silent, coupled with the denial of his right to a competent and
independent counsel or the absence of effective legal assistance when he

waived his constitutional rights, rendered the confession inadmissible under

Sec. 12, par. 3, Art. III, of the 1987 Constitution
SC:

RTC Ruling is reversed and Set Aside. Accused-Appellant is acquitted.