Title
People vs. Alcaraz
Case
G.R. No. 66509
Decision Date
Apr 25, 1985
A murder suspect is acquitted due to the inadmissibility of his extra-judicial confession and insufficient evidence of guilt beyond a reasonable doubt.
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Case Digest (G.R. No. 66509)

Facts:

  • The case involves the People of the Philippines (plaintiff-appellee) against Eduardo B. Alcaraz and Crispin Cantutay (deceased) (defendants-appellants).
  • The incident occurred on January 10, 1978, in Davao City, where Arturo Aquino was found dead in his car with multiple stab wounds.
  • A special police team was formed on January 22, 1978, to investigate the murder.
  • Crispin Cantutay was arrested on January 24, 1978, and confessed to the crime, naming Boy Luna as an accomplice.
  • During a confrontation, Cantutay retracted his confession and accused Eduardo Alcaraz, who was arrested on February 6, 1978, under the name "Rolly de los Santos."
  • Alcaraz claimed his extrajudicial confession was obtained through force and intimidation without legal counsel.
  • The trial court convicted Alcaraz of murder, sentencing him to reclusion perpetua and ordering indemnification for the victim's heirs.
  • The case was appealed to the Supreme Court, focusing on the admissibility of the extrajudicial confession and the sufficiency of evidence.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled that the extrajudicial confession of Eduardo Alcaraz was inadmissible due to being obtained through force and intimidation.
  • The Court found that the trial court erred in concluding that Alcaraz was guilty beyond reasonable doubt, as the evidence was insufficient for a conviction....(Unlock)

Ratio:

  • The Supreme Court emphasized the constitutional right against self-incrimination, stating that a confession must be voluntary to be admissible.
  • Alcaraz's extrajudicial confession was obtained under duress, supported by medical evidence of injuries consistent with maltreatment.
  • The Court referenced prior jurisprudence, asserting that con...continue reading

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