G.R. No. 117964 - Urbanes, Jr. vs. Court of Appeals

Appellant Catalino DueAas, Jr. was a convicted felon who had previously been imprisoned for homicide and later escaped from the Iwahig Prison Farm in Puerto Princesa City, Palawan on July 11, 1995.
He was charged with the murder of Elva Ramos-Jacob (also known as Elving Jacob) which allegedly occurred on November 29, 1996, in Baler, Aurora.

The murder allegedly involved a coordinated effort wherein DueAas acted as a lookout, while his accomplices—identified as Manny Gonzales and one Cesar—actively engaged in the shooting that resulted in the victim’s death.
The crime took place when the victim was shot in the head with a .38 caliber revolver and suffered fatal injuries, as later confirmed by a post mortem examination by Dr. Nenita S. Hernandez.
Details from the extrajudicial confession indicated that Benny Poblete commissioned Cesar to kill the victim, and Cesar in turn contacted DueAas to execute the plan.

On December 18, 1996, DueAas was apprehended following his attempted entry into Benny Poblete’s house, after which he was detained at the Baler Police Station.
Following his arrest, while allegedly still in police custody and with no immediate charges for the murder, DueAas was subjected to an interrogation that culminated in his extrajudicial confession on December 23, 1996.
His statement, which was initially written on pad paper and later typewritten, contained detailed narratives that the prosecution argued could have been supplied only by the perpetrator.

Medical evidence provided by Dr. Roberto A. Correa indicated that DueAas had injuries—including a three-inch lacerated wound on his right arm—and signs of violence, supporting allegations that he may have been physically coerced during detention.
Testimonies from Police Officer Noel C. Palmero and Atty. Josefina Angara (assigned to assist DueAas during the investigation) presented discrepancies regarding the duration and timing of the interrogation, with Palmero’s account evolving during cross-examination.
Rebuttal testimonies attempted to cast doubt on the claims of physical maltreatment, yet conflicting statements and the observed physical evidence raised significant constitutional questions.

DueAas alleged that his extrajudicial confession was procured through force and intimidation, including physical abuse allegedly involving mauling and water-dousing, thereby violating his constitutional rights.
He asserted that during the custodial investigation, he was not properly apprised of his right to remain silent or to consult with counsel in a timely manner, despite assurances by the police that counsel would be provided if necessary.
The Office of the Solicitor General (OSG) contended that the details in the confession were not necessarily evidence of voluntariness but could have been influenced by the conditions of his detention, including delayed legal representation.

The Regional Trial Court (RTC) found DueAas guilty beyond reasonable doubt of murder, considering evident premeditation, aggravating circumstances (including recidivism), and the details contained in his confession.
The RTC sentenced DueAas to death, ordering additional indemnification for moral damages.
The case was elevated to automatic review by the Supreme Court on the ground that significant constitutional safeguards in the taking of the confession were allegedly violated.

Whether the extrajudicial confession of Catalino DueAas, Jr. was obtained voluntarily or was the product of coercion, force, and intimidation in violation of his constitutional rights under Article III, Section 12 of the 1987 Constitution.
Whether the delayed assistance of counsel and the circumstances of the custodial investigation—as indicated by the conflicting testimonies and physical evidence—undermine the validity of the confession.
Whether the trial court erred in presuming the voluntariness of the confession based on the detailed narrative provided by the appellant, despite evidence suggesting that similar details could have been supplied by the police through prior knowledge of the case.