Case Digest (G.R. No. L-37201-02)
Facts:
In three consolidated petitions decided on March 3, 1975, the Supreme Court addressed the admissibility of extrajudicial confessions under the 1973 Constitution. In G.R. Nos. L-37201-02 (Magtoto v. Manguera), petitioner Clemente Magtoto was charged with murder in Occidental Mindoro for killing Ignacio and Eduardo Calara. His confession, executed on November 15, 1972 while in preventive custody, was admitted by the Court of First Instance of Occidental Mindoro over defense objection that he was not informed of his right to remain silent and to counsel. In G.R. No. L-37424 (Simeon v. Villaluz), petitioners Maximo Simeon and eight co-accused stood trial in Rizal for the killing of Pedro Langaoen. Their confessions, taken on October 17, 1970 without counsel, were admitted at trial in August 1973. In G.R. No. L-38929 (People v. Isnani), respondents Vicente Longakit and Jaime Dalion were tried for robbery with homicide in Zamboanga del Sur. Longakit’s confessions (dated November 7, 1
Case Digest (G.R. No. L-37201-02)
Facts:
- Parties and Cases
- G.R. Nos. L-37201-02 (March 3, 1975) – Clemente Magtoto v. Judge Miguel M. Manguera et al., Criminal Cases Nos. 394-395, CFI Occidental Mindoro (murder of Ignacio and Eduardo Calara).
- G.R. No. L-37424 (March 3, 1975) – Maximo Simeon et al. v. Judge Onofre A. Villaluz et al., Criminal Case No. CCC-VII-87, Pasig, Rizal (murder of Pedro Langaoen).
- G.R. No. L-38929 (March 3, 1975) – People of the Philippines v. Judge Asaali S. Isnani et al., Criminal Case No. 4113, CFI Zamboanga del Sur (robbery with homicide).
- Confessions and Trial Court Orders
- Magtoto – Extrajudicial confession dated November 15, 1972; admitted in evidence on June 18, 1973 despite objection that he was not informed of right to counsel/silence.
- Simeon et al. – Extrajudicial confessions dated October 17, 1970; admitted on August 16, 1973 without counsel during custodial interrogation.
- People v. Isnani – Confessions dated November 7, 1968 and September 1, 1970; rejected June 18, 1974 for failure to inform of right to counsel/silence.
Issues:
- Constitutional Scope
- Does Section 20, Article IV of the 1973 Constitution bar the admission of any confession obtained from a person under investigation who has not been informed of the right to remain silent and to counsel?
- Temporal Application
- Should the exclusionary rule of Section 20 (inadmissibility of such confessions) apply prospectively only or also to confessions taken before the Constitution’s effectivity (January 17, 1973)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)