PEOPLE OF THE PHILIPPINES, appellee,

vs.
AZCUNA and CATALINO DUEÑAS, JR., appellant.

G.R. No. 151286, 426 SCRA 666

FACTS The case involves the appellant, Catalino Dueñas, Jr., who was found guilty of the crime of murder
qualified by evident premeditation and attended by the aggravating circumstance of recidivism. The
murder of Elva Ramos-Jacob occurred on November 29, 1996, in Baler, Aurora. The appellant, who
was a convicted felon, had escaped from the Iwahig Prison Farm on July 11, 1995. He was
subsequently arrested on December 18, 1996, for theft and was detained at the Baler Police Station.
On December 23, 1996, the appellant gave an extrajudicial confession admitting his involvement in the
murder. However, the confession was obtained without the presence of a lawyer and after the appellant
had been in detention for five days. The appellant claimed that the confession was obtained through
force and intimidation.

ISSUES The main issue in this case is whether the confession given by the appellant was obtained in violation of
his constitutional rights, particularly his right against self-incrimination and his right to counsel.

RULING The Supreme Court reversed the decision of the trial court and acquitted the appellant of the crime of
murder. The Court found that the confession was obtained in violation of the appellant's constitutional
rights and was not voluntary. As a result, the confession could not be used as evidence against the
appellant. The Court also ordered the appellant's immediate release unless there was a valid reason to
return him to confinement.

Ratio:
The Court based its decision on the fact that the appellant's confession was obtained without the
presence of a lawyer and after the appellant had been in detention for five days. This violated the
appellant's right to counsel, as enshrined in the Constitution. The Court also found that the appellant's
claim of maltreatment was credible, indicating that the confession was obtained through force and
intimidation. This violated the appellant's right against self-incrimination.

The Court emphasized that the right against self-incrimination is a fundamental right that protects
individuals from being compelled to be witnesses against themselves. It is a protection against coerced
confessions and ensures that individuals are not forced to incriminate themselves. In this case, the
Court found that the appellant's confession was not given voluntarily but was a result of coercion and
intimidation.

Furthermore, the Court highlighted that the right to counsel is essential in safeguarding the rights of the
accused. It ensures that the accused is properly informed of their rights and is able to make informed
decisions during the course of the investigation and trial. In this case, the absence of a lawyer during
the appellant's confession deprived him of the guidance and protection that a lawyer could have
provided.

Based on these considerations, the Court concluded that the confession obtained in violation of the
appellant's constitutional rights could not be used as evidence against him. As a result, the Court
acquitted the appellant of the crime of murder and ordered his immediate release, unless there was a
valid reason to return him to confinement.