Case Digest (G.R. No. 206296)
Facts:
People of the Philippines v. Rodolfo Omilig y Mancia, Anacleto C. Matas, Jr., Ramil Penaflor y Laput, and Oscar Ondo, G.R. No. 206296, August 12, 2015, First Division, Perez, J., writing for the Court. The petition concerns the conviction of accused-appellant Ramil Penaflor y Laput for murder under Article 248 of the Revised Penal Code; the Regional Trial Court (RTC), Branch 5 of Lanao del Norte, City of Iligan, found him guilty in Criminal Case No. 4971, and the Court of Appeals affirmed that conviction in CA-G.R. CR HC No. 00109-MIN.
In July 1993 State Auditor Danilo Estur discovered unaccounted rice stocks at an NFA bodega under the account of Anacleto C. Matas, Jr. On Estur’s recommendation, Eduardo Betonio, Provincial Manager of NFA, Lanao del Norte, suspended Matas. On 21 August 1993 Betonio was stabbed and shot outside his rented apartment in Iligan City and later died; his wife testified that Betonio, while barely alive, whispered the names “Delfin and Matas.” The post-mortem identified stab and gunshot wounds; a knife was extracted and later shown to be owned by accused-appellant Penaflor.
An Information was filed on 7 September 1993 against Rodolfo Omilig; subsequent amendments impleaded Matas, Penaflor, and Oscar Ondo. At arraignment the accused pleaded not guilty and trial followed. The prosecution presented ten witnesses including the COA auditor, police investigators, the pathologist, the victim’s widow, the victim’s driver, and prosecutor office personnel who took Penaflor’s admissions; the defense presented eight witnesses including Omilig and several NFA employees and counsel who challenged the voluntariness and the circumstances of Penaflor’s confessions.
The records show that on 12 November 1993 police brought Penaflor to the Iligan City Police Station and he then admitted killing Betonio and said he was hired by Ondo for P15,000. Penaflor executed an extrajudicial confession before Assistant City Prosecutor Albulario (assisted by Atty. Neferteri Salise-Cristobal), and on 15 November 1993 after discharging retained counsel he executed a second confession before City Prosecutor Lagcao (assisted by Atty. Floro Cavales). The RTC admitted both confessions, acquitted Omilig, Matas and Ondo for lack of proof, and convicted Penaflor of murder, sentencing him to reclusion perpetua and awarding damages. On appeal the Court of Appeals affirmed, hold...(Pro-only)
Issues:
- Was accused-appellant Ramil Penaflor under custodial investigation (thus entitled to the protections of Article III, Section 12(1) of the Constitution and Section 2 of R.A. No. 7438) when his extrajudicial confessions were obtained?
- If custodial, were the extrajudicial confessions inadmissible because the assisting counsels were not competent and independent or not of his own choice?
- Did the prosecution prove the corpus delicti and P...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)