Facts:

The case involves Antonio Cudiamat y Angangan as the petitioner against the People of the Philippines, represented by the Hon. Emilio A. Gancayco, Venicio Escolin, and Lorenzo Relova, justices of the Court of Appeals (CA), in G.R. No. L-47753, decided on July 25, 1978. The petitioner was convicted of homicide with a penalty ranging from six years and one day of prision mayor as minimum to twelve years and one day of reclusion temporal as maximum. The incident in question occurred in December 1963 involving the death of Benjamin Angangan. Petitioner claimed self-defense in his extrajudicial confession made before Municipal Judge Francisco Camarillo of Banayoyo, Ilocos Sur. The confession was made on December 10, 1963, and was sworn to after the judge translated its contents into the Ilocano dialect. During the proceedings, the Court of Appeals found that the confession was voluntary and had no signs of coercion. The lower court dismissed petitioner's plea for reversal based o

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Facts:

1. Background of the Case:

   • Petitioner Antonio Cudiamat y Angangan was convicted of homicide by the Court of Appeals. The sentence imposed was six years and one day of prision mayor as a minimum to twelve years and one day of reclusion temporal as a maximum.
   • The conviction was based on his confession, which he made as a suspect in the killing of Benjamin Angangan.

2. Confession Details:

   • The confession was made on December 16, 1963, before Municipal Judge Francisco Camarillo of Banayoyo, Ilocos Sur.
   • Judge Camarillo testified that he read the statement to the petitioner in the Ilocano dialect, and the petitioner affirmed its truthfulness before signing it.
   • Additional clarificatory questions were asked by the judge, and the answers were incorporated into the confession as an addendum.

3. Legal Context:

   • The petitioner argued that his confession should be inadmissible because he was not informed of his right to counsel during custodial interrogation, invoking the expanded constitutional right against self-incrimination under the 1973 Constitution.
   • The confession was made before the 1973 Constitution took effect on January 17, 1973.

4. Self-Defense Claim:

   • The petitioner claimed self-defense, but the Court of Appeals found that his testimony lacked corroboration and was inconsistent with the evidence.
   • The victim sustained eleven wounds, while the petitioner emerged unscathed, casting doubt on his claim of self-defense.

Issue:

1. Admissibility of the Confession:

   • Whether the petitioner’s extrajudicial confession, made without the assistance of counsel and before the effectivity of the 1973 Constitution, is admissible in evidence.

2. Retroactivity of Constitutional Rights:

   • Whether the constitutional right to counsel during custodial interrogation, as provided under the 1973 Constitution, applies retroactively to confessions made before its effectivity.

3. Validity of Self-Defense Claim:

   • Whether the petitioner’s claim of self-defense was sufficiently proven to warrant acquittal.

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Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)