Title
People vs. Inguito
Case
G.R. No. L-53497
Decision Date
Oct 18, 1982
Accused-appellant acquitted as coerced confession deemed inadmissible; circumstantial evidence insufficient to prove guilt beyond reasonable doubt.
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Case Digest (G.R. No. L-53497)

Facts:

Background of the Case

  • Accused-appellant Godofredo Inguito, along with co-accused Bienvenido Auguis and Salvador Petallino, was charged with the murder of Epifanio Cajes.
  • The crime allegedly occurred on January 7, 1979, in Bato, Leyte, where the accused conspired to attack, assault, and stab the victim using wooden sticks and a stainless kitchen knife, resulting in his death.

Trial Court's Decision

  • The Court of First Instance of Baybay, Leyte, convicted the accused based on their extra-judicial confessions and sentenced them to Reclusion Perpetua.
  • The trial court also ordered them to indemnify the victim's heirs with P12,000.00.

Accused-Appellant's Defense

  • Godofredo Inguito retracted his confession, claiming it was obtained through force and intimidation. He alleged that he was mauled in a toilet and threatened by a guard to sign the affidavit.
  • He testified that he was not assisted by counsel during the investigation, and the contents of the affidavit were not read to him in a language he understood.

Prosecution's Evidence

  • The prosecution relied on the extra-judicial confessions of the accused and the testimony of Felimon de Veyra, who claimed to have seen the accused with the victim on the night of the crime.
  • However, de Veyra admitted that he did not witness the actual killing and only concluded the accused's guilt based on their behavior after the incident.

Issue:

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Ruling:

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Ratio:

  1. Nullity of Coerced Confessions: Extra-judicial confessions obtained through force, intimidation, or in violation of the accused's constitutional rights (right to remain silent, right to counsel, and right to be informed of these rights) are inadmissible in evidence. Such confessions are unreliable and violate humanitarian principles.
  2. Presumption of Innocence: The prosecution must prove the guilt of the accused beyond a reasonable doubt. Circumstantial evidence, unless strong and conclusive, cannot overcome the presumption of innocence.
  3. Insufficient Evidence: The testimony of Felimon de Veyra was speculative and did not provide direct evidence linking the accused to the crime. Without the inadmissible confession, the prosecution's case lacked the necessary proof to convict.
  4. Constitutional Safeguards: The Court emphasized the importance of adhering to constitutional protections during custodial investigations to ensure the integrity of the judicial process.


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