G.R. No. 181318 - People vs. Agojo y Luna

On July 31, 1976, in Quezon City, Fabian Galvan was attacked by several persons who stoned him and hit him with beer bottles; finally, one stabbed him to death.
The actual knife-wielder was identified as Mario del Mundo, who was at large and could not be prosecuted.
Alberto Opida and Virgilio Marcelo were charged and convicted of murder as conspirators, based largely on extrajudicial confessions and the theory of interlocking confessions.

The trial judge demonstrated clear hostility and partiality against the accused.
The judge obsessively focused on Opida’s tattoos and criminal background, even requiring him to remove his shirt to examine the tattoos.
The judge made insinuations regarding Opida’s mental condition and alleged police torture, questioning his credibility and integrity with a malicious tone.
During the trial, the judge took over cross-examination of Marcelo and aggressively questioned him about drug addiction, gang membership, family matters, and criminal record, impeding defense counsel’s ability to interrogate.
The judge’s interrogation of the defense witness, Lilian Layug, was marked by mockery, irrelevant questions, and insinuations that compromised the witness’s credibility and dignity.
Both accused admitted to extrajudicial confessions, which were secured without counsel and challenged on the basis of violations of constitutional rights and improper interrogation methods.

The accused claimed their extrajudicial confessions were obtained without observance of constitutional rights including the right to counsel.
Opida testified that he was physically abused by police during investigation.
The trial judge dismissed the accused’s protests and admitted the confessions as evidence, using them to corroborate the conspiracy charge.
The accused, despite a notorious past and gang membership, were still entitled to the presumption of innocence and due process guarantees.
The trial judge exhibited evident partiality and pre-judgment against the accused.

Whether the trial judge violated the accused’s right to an impartial and neutral tribunal as guaranteed under due process.
Whether the extrajudicial confessions obtained without the assistance of counsel and in alleged violation of constitutional rights can be admitted as evidence to convict the accused.
Whether the conviction and death sentences imposed on the accused were valid under the circumstances exhibiting denial of due process and constitutional protections.