Case Digest for PEOPLE VS.

TABOGA 376 SCRA 505 (2002) Facts and Issue

FACTS:
Francisca Tubon was robbed, stabbed and burned beyond recognition when her house
was set on fire.

Evidence pointed out to Edralin Taboga as the perpetrator of the crime. Hence, Taboga
was brought to the police station for investigation where he was asked by SPO1 Panod
whether he was the one who did it or not to which he answered in the affirmative. SPO1
Panod prepared a written extra-judicial confession for Taboga. However, during the
inquest, Taboga refused to sign the confession upon the advice of his lawyer.

On April 2, 1998, Mr. Mario Contaoi, a radio announcer interviewed the suspect where,
again, Taboga admitted killing the deceased and setting her and her house on fire.

Accused-appellant Edralin Taboga raised the defense of denial and alibi.

Accused-appellant also claimed that he was maltreated by the policemen and forced to
admit the crime. Regarding his admission to radio announcer Mario Contaoi, he narrated
that the interview was held inside the investigation room of the police station where
policemen were present. Thus, he had to admit the crimes because he was afraid of the
policemen. Moreover, relatives of the deceased beat him up by kicking him, hitting him
with a chair, slapping him and punching him on the head and face.
Subsequently, Taboga was charged with the case of special complex crime of Robbery
with Homicide as well as Arson. Both cases were then tried jointly.

The Regional Trial Court of Cabugao, Ilocos Sur rendered judgment finding Taboga
guilty beyond reasonable doubt of the special complex crime of Robbery with Homicide
and Destructive Arson.

ISSUE:
Whether or not the extrajudicial confession made by the accused to a radio reporter who
was acting as an agent for the prosecution is in violation of the procedural safeguards
enshrine in the Constitution and admissible as evidence.