Title: People vs.

Muleta Name of Digester: John Fredrick Bucu

G.R. No. 130189 Date: Ponente:

June 25,
1999
Subject / Syllabus Topic: Interpretation and Construction of Penal Statutes

Petitioner: People of the Philippines Respondent: Domingo R. Muleta

Doctrine (if applicable): 1987 Constitution Art. 3 Sect 12 & Sect 14

R.A. 7438- AN ACT DEFINING CERTAIN RIGHTS OF PERSON ARRESTED, DETAINED OR UNDER
CUSTODIAL INVESTIGATION AS WELL AS THE DUTIES OF THE ARRESTING, DETAINING AND
INVESTIGATING OFFICERS, AND PROVIDING PENALTIES FOR VIOLATIONS THEREOF

Recit Summary: Domingo Muleta forced himself on Charito Delgado, raping her and killing her by
stabbing her in the neck. The investigation of the NBI was done and invited Muleta for questioning.
Danilo Delgado, Charito’s uncle, testified that during her wake, Muleta became hysterical and muttered
“Patawarin mo ako Charito, ikaw kasi lumaban pa, nakakahiya, mabuti pang mamatay na.” Muleta alleges
that during the NBI’s questioning, he was tortured and forced the procurement of his confessions and
sign a document while there was no lawyer present as he signed the document. Lower court decided that
Muleta must have a penalty of reclusion perpetua. Hence, this appeal. Issue is W/N the extrajudicial
confession by Muleta was admissible. The Court held that it is NOT admissible because the NBI violated
the constitution for not letting Muleta choose his counsel during the confession and document-signing,
and also violating R.A. 7438 for not according Muleta the right of counsel from the time he was brought
to the NBI office. And that the NBI-procured lawyer Atty. Daquis was only present the day AFTER the
questioning. Prosecution’s other evidence was weak, while their strongest is the extrajudicial questioning
which was already inadmissible. Court ruled that the appeal is granted and that Muleta be acquitted.
Facts:
 On April 30, 1999, just a few hours passed midnight, accused DOMINGO MULETA y ROCERO had
forced himself on Charito M. Delgado without her consent, raping her while using force and intimidation as
the latter was unconscious; and thereafter accused Domingo Muleta y Rocero by reason or on occasion of
the said rape incident, taking advantage of his superior strength, stabbed Charito M. Delgado in the neck
and at the back causing the instantaneous death of the latter.
 Based on the investigation of the NBI, during the time of the disappearance of Charito, Domingo Muleta
(uncle of victim) was suspected of performing the crime for his unexplained disappearance coinciding with
the disappearance of victim. Domingo Muleta was then invited for questioning.
 Danilo Delgado testified that during the wake of Charito Delgado, appellant (Muleta) became hysterical,
crying, shaking his head and muttering: “Patawarin mo ako Charito, ikaw kasi lumaban pa, nakakahiya,
mabuti pang mamatay na.”
 Appellant on the other hand alleges that he was tortured in his questioning by the NBI; that he was forced
to sign a document which he was not able to read, that he was forced to sign the document because he could
no longer bear the torture; that he did not have a lawyer at that time.
 The lower court decides a penalty of reclusion perpetua. Hence this appeal.

Issue/s: Ruling:
- W/N the extrajudicial confession made by The appeal is GRANTED. Assailed Decision is
Domingo Muleta was admissible REVERSED and VACATED. Domingo Muleta is
ACQUITTED for insufficiency of evidence.
Holding:
No. A confession is not admissible unless the prosecution satisfactorily shows that it was obtained within
the limits of Art. 3 sect. 12 of the Constitution, which reads:
“(1) Any person under investigation for the commission of an offense shall have the right to be informed of his right to remain
silent and to have competent and independent counsel preferably of his own choice. If the person cannot afford the services of
counsel, he must be provided with one. These rights cannot be waived except in writing and in the presence.”
“(3) Any confession or admission obtained in violation of this or section 17 hereof shall be inadmissible in evidence”

The extrajudicial confession made by Muleta under the NBI’s investigation is not admissible because
there was no counsel that was present during Muleta’s confession and waiving of his rights. Even after
appellant actually admits to the execution of the said confession, it lacked the assistance of a counsel,
rendering it inadmissible as evidence in court.

Flagrantly violated in the present case were the appellant’s rights to be informed of his rights under custodial
investigation, his right to counsel, as well as this right to have said counsel present during the waiver of his
rights under custodial investigation.

Separate Opinions:
Notes: Topic is Interpretation and Construction of Penal Statutes
Cited article is from Constitution- Art. 3 sect. 14 (2)

Presumption of Innocence- Muleta’s strange actions in the wake of Charito does not connote guilt. Only
suspicion. But in criminal prosecutions, the accused shall be presumed innocent until the contrary is
proved.
Right to Counsel- Even if accused admittedly confessed, the NBI did not follow the law with regards to
their investigation. They did not inform the accused of his rights, one of those is the right to be heard by
himself and counsel. Thus, making Muleta’s confession inadmissible in court as it violates the
constitution. If the NBI followed the law, the decision might have been different.