Title
People vs. Agustin y Paraggua
Case
G.R. No. 247718
Decision Date
Mar 3, 2021
Jaynard Agustin was acquitted of Rape with Homicide after the Supreme Court ruled his extrajudicial confession inadmissible due to violations of his constitutional rights, leading to insufficient evidence for conviction.

Case Digest (G.R. No. 247718)
Expanded Legal Reasoning Model

Facts:

  • Background and Indictment
    • On November 3, 2010, an Information was filed against Jaynard Agustin y Paraggua for Rape with Homicide under Article 266-A No. 1(a) and (d) in relation to Article 266-B (4th par.) and Article 249 of the Revised Penal Code as amended by R.A. No. 8353, alleging that on November 1, 2010, he forcibly raped minor AAA, 12 years old, in a sugarcane plantation in Cagayan and strangled her to death to conceal the crime.
    • During arraignment, Agustin pleaded not guilty after the Information was read and explained to him in Ilocano.
  • Prosecution Evidence
    • BBB (mother of AAA) testified as to the victim’s age and death, but her testimony was largely dispensed with by stipulation on civil indemnity (P50,000).
    • Dr. Francisco Romulo D. Villaflor, medico-legal officer, conducted the November 2, 2010 post-mortem of AAA and found:
      • Eight injuries on the body including hematomas and abrasions on the neck consistent with strangulation (cause of death: asphyxia by strangulation).
      • Three fresh genital injuries—vaginal abrasion with hematoma, hymenal laceration (5 o’clock position), and fourchette laceration—indicative of forceful sexual intercourse.
    • Atty. Luis Donato, Jr. assisted during Agustin’s extrajudicial confession on November 2, 2010, at the local police station. He testified that:
      • He was requested by police to assist Agustin, translating questions from English to Ilocano and vice versa.
      • Agustin was read his rights, insisted on confessing, recounted rape and killing of AAA, and affixed his thumbmark to the typewritten confession, which bore signatures of the investigator and counsel.
    • Barangay Captain Alfredo Ruam was notified and initially presented but his testimony was not continued.
    • Investigating Officer PO3 Joel Mora’s testimony was dispensed with by stipulation; the extrajudicial confession document (Exh. H) was offered and admitted.
  • Defense Evidence
    • Accused Agustin testified under oath, denying any involvement in the rape-homicide, denying knowledge of the confession document, claiming illiteracy and inability to read or write, and disavowing acquaintance with Atty. Donato, Jr.

Issues:

  • Whether the trial court erred in admitting Agustin’s extrajudicial confession despite constitutional and statutory infirmities.
  • Whether the remaining evidence proved Agustin’s guilt beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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