Case Digest: People vs Dela Cruz – 224 SCRA 506; G.R. NO. 118866-68; September 17, 1997;

Facts:

Rodolfo de la Cruz was convicted of multiple murder.

The murders occurred on June 23, 1992, in Cainta, Rizal. The victims were Teodorico M. Laroya, Jr., his 12-year-old daughter Karen Verona D. Laroya, and his 10-year-old son John Lester D. Laroya.

The bodies of the victims were discovered in their residence by their neighbors. They had been stabbed multiple times, and one of the victims showed signs of sexual assault.

Two witnesses testified in court, one of whom witnessed the discovery of the bodies, and the other had interactions with the accused on the night of the murders.

Accused-appellant was arrested and interrogated by SPO1 Carlos R. Atanacio, Jr. during which he allegedly confessed to the crimes and signed an extrajudicial confession.

The appellant, acting as his own witness, had difficulty expressing himself and had a speech impediment. He had limited education, having only completed fourth grade, and could not read or write, except for his signature.

While he admitted being at the victims' residence on the night of the murders, he vehemently denied killing them, stating that he left them alive and well when he went to his brother's place.

Accused-appellant claims that he was not fully informed of his constitutional rights and was not provided with a counsel of his choice during the custodial investigation. He also alleges that he was tortured into signing the confession. He denied meeting his supposed counsel and insisted on his innocence.


Issues:

WoN the accused-appellant was fully and appropriately informed of his constitutional rights during the custodial investigation.

WoN the extrajudicial confession obtained from accused-appellant is admissible as evidence.

WoN there is sufficient evidence, other than the confession, to support accused-appellant's conviction.

Held:

The Supreme Court reversed the judgments of the RTC and acquitted accused-appellant Rodolfo de la Cruz. The court held that the extrajudicial confession was inadmissible as evidence due to violations of accused-appellant's constitutional rights during the custodial investigation. The court found that accused-appellant was not properly informed of his rights, particularly regarding the provision of a counsel if he could not afford one. The presence and independence of the counsel provided by the law enforcers were also questionable. Moreover, the confession was not corroborated by other evidence of guilt, and the prosecution relied mainly on circumstantial evidence. Therefore, accused-appellant's conviction could not be sustained, and he was ordered to be released unless there were other lawful reasons for his continued incarceration

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