14. People v Deniega 251 SCRA 626 (637), People v. Daniega, Dec.

29, 1995

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.