28. People v. Camat then went away with their loot.
Fortunately one of the victims
survived leading to their eventual arrest and conviction. G.R. No. 112262 April 2, 1996 Relevant Issue: TOPIC: RIGHTS UNDER CUSTODIAL INVESTIGATION Was there a violation of the rights of the accused when he executed the said confession? Summary: Ruling: Yes This case is an instant appeal of the decision of the Regional Trial Court (RTC) finding the accused Camat guilty Ratio: of the special complex crime of robbery with homicide and frustrated homicide. The accused alleges that the court erred in The trial court cannot rely on the extrajudicial admitting as evidence the extrajudicial confession of the confession of appellant Camat as a basis for their conviction accused since the same was obtained in violation of his rights. because such confession was obtained during custodial The SC agrees with this contention however the evidences investigation in violation of their constitutional rights. In the where strong enough even without the confession case at bar absent is the showing that appellants were duly advised of the mandatory guarantees under the Bill of Rights, Doctrine: their confessions made before Patrolman Cariño are inadmissible against them and cannot be used in support of The accused has the right to be informed about his their conviction. This is in view of the rights of the accused as rights and he must be able to duly exercise the same. In cases provided in the case of Enrile: where the accused was duly informed and thereafter executed an extrajudicial admission with the assistance of a counsel, At the time a person is arrested, it shall be the duty of such admission is admissible as evidence in court. Also the the arresting officer to inform him of the reason for the arrest right to confront a witness against the accused is limited to the and he must be shown the warrant of arrest, if any. He shall be trial and does not cover custodial investigation. informed of his constitutional rights to remain silent and to counsel, and that any statement he might make could be used Facts: against him. The person arrested shall have the right to The victims Sinoy and Penalver were walking along communicate with his lawyer, a relative, or anyone he chooses Quirino Ave. when they observed that the accused and another by the most expedient means - by telephone if possible - or by companion seems to be following them. In order for them to letter or messenger. It shall be the duty of the arresting officer get away from those who were tailing them the victims crossed to see to it that this is accomplished. No custodial investigation the street but the accused persisted and followed them as they shall be conducted unless it be in the presence of counsel cross the street eventually they commenced with their plan engaged by the person arrested, by any person on his behalf, or which is to rob the victims and to kill them afterwards. They appointed by the court upon petition either of the detainee himself or by anyone on his behalf. The right to counsel may be waived but the waiver shall not be valid unless made with the assistance of counsel. Any statement obtained in violation of the procedure herein laid down, whether exculpatory or inculpatory, in whole or in part, shall be inadmissible in evidence. It is also important to note that the right of confrontation is specified as a right of the accused at the trial. It must be reiterated that an accused's constitutional right to meet the witnesses face to face is limited to proceedings before the trial court. Accordingly, appellants' reliance upon this constitutional right is evidently misplaced as the same is available to him at the trial and not during a custodial investigation.