Facts:

The case involves the People of the Philippines as the plaintiff and Nicanor Jimenez and Teofilo Hernando as the accused. The events transpired on July 17, 1973, in Pangil Bay, Misamis Occidental, where Staff Sergeant Albino Panelo, in charge of the Integrated Civilian Home Defense (IC-HDF), along with several barrio councilors, was patrolling the area to apprehend individuals engaged in illegal trawl fishing. During their patrol, they apprehended two pumpboats and their occupants. Later that night, they spotted a third pumpboat, which was manned by Nicanor Jimenez and Teofilo Hernando. After giving instructions to one of the councilors, Fabiano Fuentes, to follow them, the group lost track of Fuentes and the third pumpboat. Two days later, Fuentes' body was discovered floating in the water, with a postmortem examination revealing that he died from asphyxia.

Nicanor Jimenez was arrested on August 2, 1973, and Teofilo Hernando on August 3, 1973. The City Fiscal filed an...

Facts:

1. Background and Patrol Operation:
   Due to rampant trawl fishing in Pangil Bay, Staff Sergeant Albino Panelo of the Constabulary, along with Barrio Councilors Gaudioso Dungon, Fabiano Fuentes, Pascual Taylaran, and Angel Enriquez, formed teams to patrol the area and apprehend trawl fishers. On July 17, 1973, they apprehended two pumpboats with occupants Engracio Sabandal, Juan Temporada, Camilo Bayonas, and Wilfredo Chasol.

2. Chase and Disappearance of Fabiano Fuentes:
   Later, they spotted a third pumpboat manned by Nicanor Jimenez and Teofilo Hernando. Sgt. Panelo instructed Fabiano Fuentes to tie the third pumpboat and follow them. However, Fuentes and the third pumpboat disappeared. After an intensive search, Fuentes' body was found floating two days later, with postmortem examination revealing death by asphyxia.

3. Arrest and Charges:
   Nicanor Jimenez and Teofilo Hernando were arrested on August 2 and 3, 1973, respectively. They were charged with murder based on sworn statements from witnesses. The case was dismissed provisionally due to the non-appearance of prosecution witnesses but was refiled on January 17, 1974, with only Jimenez arrested.

4. Trial and Conviction:
   The trial court convicted Jimenez of murder based on the testimony of Sgt. Panelo and Gaudioso Dungon, who claimed to have recognized Jimenez during the chase. The court also considered Jimenez's extra-judicial confession, which he later repudiated, claiming it was coerced.

Issue:

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Ruling:

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Ratio:

1. Identification Evidence:
   The Court emphasized that identification evidence must be clear and unequivocal. In this case, the testimonies of Panelo and Dungon were insufficient and unreliable, as they did not know Jimenez prior to the incident and their accounts were inconsistent.

2. Constitutional Safeguards:
   The Court applied the Miranda doctrine, ruling that any confession obtained without informing the accused of their rights to remain silent and to counsel is inadmissible. Jimenez's confession was obtained in violation of these safeguards, rendering it invalid.

3. Right Against Self-Incrimination:
   The Court reaffirmed the importance of protecting the accused's constitutional rights, particularly the privilege against self-incrimination, to prevent coerced confessions and ensure a fair trial.