Case Digest (G.R. No. 213137)
Facts:
In the evening of June 23, 1992, the bloodied bodies of Teodorico M. Laroya, Jr. and his children, twelve-year-old Karen Verona and ten-year-old John Lester, were found with knives still protruding from their torsos in their home at 13 Emerald Street, Greenpark Village, Cainta, Rizal. Karen bore external signs of sexual assault. No eyewitnesses to the killings were presented, although two neighbors, Harold Jim F. Balocating and Anita F. Pangan, later testified about discovering the bodies and appellant’s presence in the village shortly before the murders. On June 27, 1992, police arrested Rodolfo de la Cruz, alias Rodolfo Domingo or “Ompong,” the victim’s brother-in-law, at Fort Bonifacio and brought him to the Cainta police station for interrogation by SPO1 Carlos R. Atanacio, Jr. Appellant, who had only completed elementary schooling and was unable to read or write, allegedly signed an extrajudicial confession at 11:00 A.M. in the presence of Atty. Lorenza Bernardino-VillanuevCase Digest (G.R. No. 213137)
Facts:
- Discovery of crime
- On the evening of June 23, 1992, the bodies of Teodorico M. Laroya, Jr. and his children Karen Verona (12) and John Lester (10) were found in their Cainta, Rizal home, each bearing multiple stab wounds and a protruding knife; Karen showed signs of sexual assault.
- Neighbors Harold Balocating and Anita Pangan testified they discovered the bodies; Pangan saw appellant—brother-in-law of the principal victim—buy candies at about 9:00 PM that night.
- Arrest, interrogation, and confession
- On June 27, 1992, police arrested appellant at his brother’s house in Fort Bonifacio; SPO1 Atanacio interrogated him at Cainta police headquarters beginning around 9:00 AM.
- Police claim they informed appellant of his right to remain silent and to have counsel—and that Atty. Lorenza Bernardino-Villanueva was present—before he signed an extrajudicial confession at 11:00 AM.
- Appellant’s profile and defense
- Appellant completed only grade four, is illiterate with a speech impediment, denied meeting any counsel during interrogation, and asserted he was tortured into confession.
- He admitted visiting the Laroya residence but claimed an alibi—leaving the victims alive to stay at his brother’s house—and denied committing the murders.
Issues:
- Whether appellant’s extrajudicial confession is admissible given alleged defects in informing him of constitutional rights.
- Whether police complied with the requirement to inform an indigent suspect of the right to appointed counsel and to secure a valid waiver in writing and in counsel’s presence.
- Whether, absent a valid confession, the remaining evidence suffices to sustain appellant’s conviction for multiple murder.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)