Case Digest (G.R. No. 103499)
Facts:
In People of the Philippines vs. Rey Daniega y Macoy and Hoyle Diaz y Urnillo (G.R. No. 103499, December 29, 1995), the body of Marlyn Canoy was discovered on August 31, 1989, in a secluded area beside Mt. Carmel Church in Quezon City. The victim’s hands were bound, she bore thirty-nine stab wounds, and there was evidence of brutal physical and sexual assault. Police arrested Daniega—formerly Marlyn’s boyfriend—on information from friends that Marlyn had recently ended a “stormy relationship” with him. During a custodial investigation, Daniega allegedly confessed to raping and stabbing Marlyn. Investigators then questioned Diaz, who gave a sworn statement corroborating many details of Daniega’s affidavit, admitting participation in the rape but denying the homicide. An Information for Rape with Homicide was filed in the Regional Trial Court of Quezon City. At trial, the prosecution relied mainly on the two extra-judicial confessions. The defense asserted that the confessions werCase Digest (G.R. No. 103499)
Facts:
- Discovery of the victim
- On or about August 29, 1989, the naked body of Marlyn Canoy was found in a heap of garbage beside Mt. Carmel Church, New Manila, Quezon City.
- The corpse bore 39 stab wounds and showed signs of brutal physical and sexual assault; her hands were tied behind her back with a shoestring and pieces of her own clothing.
- Arrests and extrajudicial confessions
- On August 31, 1989, police arrested Rey Deniega y Macoy based on information that Canoy last was seen with him; friends testified to their stormy relationship and his failed reconciliation attempts.
- Investigators obtained a custodial confession from Deniega implicating himself and appellant Hoyle Diaz y Urnillo in rape and homicide; Diaz gave a similar confession, admitting rape but denying the killing.
- Trial court proceedings
- An Information was filed charging both appellants with rape with homicide, alleging they conspired to sexually assault and stab Canoy to death.
- Appellants moved to exclude their confessions, claiming they were coerced (electrocution, water torture), obtained without warrants or counsel; the trial court denied their Demurrer to Evidence.
- The trial court credited the extrajudicial confessions—bolstered by two IBP lawyers who purportedly assisted the accused—convicted both of rape with homicide, sentenced each to reclusion perpetua, and awarded P50,000 damages to the heirs.
Issues:
- Whether the extrajudicial confessions of appellants were voluntary and duly executed, given that custodial investigations allegedly occurred without competent, independent counsel and possibly under coercion.
- Whether, absent valid confessions, the prosecution presented sufficient evidence to sustain convictions for rape with homicide.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)