Case Digest (G.R. No. 98252) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Rene Januario y Roldan and Efren Canape y Bayot (G.R. No. 98252, February 7, 1997), appellants Rene Januario and Efren Canape were charged in the Regional Trial Court of Cavite, Branch XVIII, with violation of Section 14, last sentence, of Republic Act No. 6539 (Anti-Carnapping Law) for the carnapping and killing of a jeepney driver and conductor on September 4, 1987 in Silang, Cavite. Co-accused Santiago Cid, Eliseo Sarita (“Toto”) and Eduardo Sarinos (“Digo”) were likewise charged, although Sarita and Sarinos remained at large. After arraignment in February 1989, the National Bureau of Investigation (NBI) conducted custodial inquiries in Naga City and later at its Manila office. The principal evidence were the extrajudicial confessions of Januario and Canape, taken on March 27–28, 1988 with the assistance of Atty. Carlos Saunar, who was applying for NBI employment. At trial the prosecution also presented testimony from NBI agents, witnesses, an Case Digest (G.R. No. 98252) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents
- On September 4, 1987, the driver and conductor of an Isuzu passenger jeepney were stabbed to death and the jeepney carnapped in Silang, Cavite.
- On November 7, 1988, an Information was filed charging Rene Januario and Efren Canape (with co-accused Santiago Cid, Eliseo Sarita @ Toto, and Eduardo Sarinos @ Digo) with violation of R.A. No. 6539 (Anti-Carnapping Law).
- Pre-trial and Investigation
- Arraignment and Pleas
- On February 7, 1989, Januario and Canape pleaded not guilty, assisted by public counsel.
- On May 30, 1989, Cid pleaded not guilty; Sarita and Sarinos remained at large.
- NBI Inquiry and Arrests
- NBI investigation traced disposition of the jeepney through Vicente Pons and Myrna Temporas; bodies of the victims were recovered in a sugarcane plantation.
- Appellants and Cid were arrested in Camarines Sur; the jeepney was recovered and returned to Manila.
- Custodial Statements
- On March 27, 1988 (Naga City) and March 28, 1988 (Manila), appellants gave sworn statements before NBI agents.
- Atty. Carlos Saunar, then applying for NBI employment, assisted and signed the statements as “counsel.”
- Trial Proceedings
- Presentation of Evidence
- Prosecution presented seven witnesses, documents, and photographs.
- Defense initially indicated intention to file a demurrer to evidence but failed to do so timely.
- Rebuttal and Additional Evidence
- Atty. Saunar was called as an additional/rebuttal witness after prosecution rested, over defense objection.
- Defense witness Cid testified but offered no evidence on behalf of Januario and Canape.
- Judgment of the Trial Court
- On June 27, 1990, the RTC convicted Januario and Canape of carnapping with homicide, imposing reclusion perpetua, and awarded damages.
- Cid was acquitted for lack of evidence.
Issues:
- Trial Procedure
- Whether the admission of Atty. Saunar’s testimony after prosecution closure was irregular and prejudicial.
- Whether the trial court erred in disallowing the defense demurrer to evidence.
- Constitutional Right to Counsel and Confessions
- Whether the extra-judicial confessions and admissions of appellants were admissible despite constitutional guarantees to “competent and independent counsel preferably of his own choice.”
- Whether uncounselled oral admissions and confessions constitute “fruit of the poisonous tree” and must be excluded.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)