Case Digest (G.R. No. L-63861)
Case Digest (G.R. No. L-63861)
Facts:
People of the Philippines v. Sabas Poyos alias Boy, Liliosa Poyos alias Lily and Florencio Poyos alias Lor, Accused; Florencio Poyos alias Lor, Accused‑Appellant, G.R. No. 63861, August 19, 1986, Supreme Court En Banc, Cruz, J., writing for the Court.On August 12, 1980, seventy‑seven‑year‑old Paula Angoy was found dead in Balilihan, Bohol. Three persons — Sabas Poyos, Liliosa Poyos, and Florencio Poyos — were accused of killing her by striking her on the neck with a piece of wood. Only Florencio was arraigned and tried because the other two had fled and remained at large. The trial court convicted Florencio of murder with qualifying and aggravating circumstances and sentenced him to death.
Initial medical certification by Dr. Vito Inting attributed death to cerebral hemorrhage based on information from Sabas Poyos; the victim had already been buried. About a year later suspicions prompted exhumation and an autopsy by PC medico‑legal officer Dr. Ladislao V. Diola, Jr., who found a contusion at the nape compatible with massive hemorrhage to the brain base; no other injuries were noted.
Investigator Pat. Ranulfo Tabudlong interrogated Florencio and secured an extrajudicial confession, signed before Clerk of Court Maria Cleofe L. Clarin; the confession was introduced at trial and Clarin testified it was freely signed after the affiant acknowledged the statement. Florencio testified in his own defense, denied the killing, claimed the victim was already dead when he arrived, said he merely assisted in moving the body and attended the wake, and asserted he was illiterate, signed only his name, and had been coerced and threatened by police into signing. He also alleged additions had been intercalated in the statement.
The purported waiver of rights recorded before the interrogation read that Florencio understood he had the right to remain silent and to "hire a lawyer," and that he agreed to continue the investigation "even if for the moment you have no lawyer to help you." The prosecution maintained the confession complied with constitutional requirements, that Florencio was warned and knowingly waived counsel, and that no coercion occurred. The trial court relied heavily on the extrajudicial confession in convicting; the case was brought to the Supreme Court on appeal.
Issues:
- Was the extrajudicial confession admissible under Article IV, Section 20 of the 1973 Constitution — i.e., was there a valid, voluntary, and knowing waiver of the right to counsel and freedom from coercion?
- If the confession is inadmissible, did the prosecution nevertheless prove guilt beyond reasonable doubt so as to sustain the conviction?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)