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
Case Digest (G.R. No. 66509)
Facts:
The case involves the People of the Philippines as the plaintiff-appellee against Eduardo B. Alcaraz and Crispin Cantutay (deceased) as the defendants-appellants. The events transpired on January 10, 1978, in Davao City, where Arturo Aquino was found dead inside his car, having sustained multiple stab wounds. Following the incident, a special police team was formed on January 22, 1978, to investigate the murder. Crispin Cantutay was apprehended on January 24, 1978, and subsequently confessed to the crime, implicating a certain Boy Luna as his accomplice. However, during a confrontation, Cantutay retracted his statement and instead named Eduardo Alcaraz, who was initially arrested on February 6, 1978, under the mistaken identity of "Rolly de los Santos." Alcaraz was subjected to an extrajudicial confession, which he later claimed was obtained through force and intimidation without the presence of legal counsel. The trial court found Alcaraz guilty of murder, sentencing him to reclusion perpetua and ordering him to indemnify the heirs of the victim. The case was appealed to the Supreme Court, which focused on the admissibility of the extrajudicial confession and the sufficiency of evidence against Alcaraz.