G.R. No. 62305 - Sampaga y Delos Reyes vs. People

The accused, Angel Sampaga y de los Reyes, was charged with homicide for the killing of his cousin, Marciano Soria y Posedia, as alleged in the information filed before the Court of First Instance of Rizal.
The information alleged that on or about April 7, 1976, in Quezon City, the accused, without justifiable motive, wilfully and unlawfully attacked Marciano Soria with a knife, inflicting a fatal stab wound on his chest.

On the evening of April 7, 1976, at approximately 9:30 pm, a drinking session ensued at the residence of Angel Sampaga. The gathering involved Marciano Soria (the victim), the accused, and other individuals including Carlos Eduque, Herminigildo Soria (the deceased’s brother), and Eduardo de Castro.
A heated argument broke out between Angel Sampaga and Marciano Soria during the drinking, leading to a violent altercation. Friends present, such as Eduardo de Castro and Carlos Eduque, left the scene, with Carlos later returning to assist upon hearing of the stabbing.

Following the incident, Marciano Soria was rushed to the hospital where he later succumbed due to cardiorespiratory arrest caused by shock and intra-abdominal hemorrhage from a deep stab wound.
A medico-legal necropsy detailed the characteristics of the wound, describing it as an 18-centimeter-deep, transfixing injury that fractured the 8th rib and lacerated internal organs, suggesting an intentional and forceful thrust.
On May 21, 1976, a police investigation was conducted. The accused was informed of his constitutional rights, including the right to remain silent and to have counsel present during the interrogation.

The accused voluntarily made an extra-judicial confession during the investigation. His confession was recorded in a sworn statement in which he admitted to killing Marciano Soria using a “kutselyo” (knife).
The confession also included details on the location of the weapon; subsequently, the accused led the police to his house where the fatal knife (Exhibit I) was recovered.
Although three witnesses (Carlos Eduque, Eduardo de Castro, and Herminigildo Soria) were interviewed, their statements—which denied their presence during the stabbing—were not presented in court, leaving the extra-judicial confession as the primary evidence against the accused.

Prior to and during the interrogation, the accused was orally informed by Detective Joy Diaz of his rights under Section 20, Article IV of the 1973 Constitution, which guarantees the right to remain silent and to have counsel.
Despite adherence to the warning protocol, the accused was not later afforded the presence of counsel or an opportunity to secure one during the investigation.
The accused attempted to invoke self-defense by claiming that during a struggle with the victim, the knife accidentally grazed or struck him—a claim contradicted by the depth and nature of the victim’s fatal wound, as established by the autopsy findings.

Whether the extra-judicial confession, obtained during the custodial investigation without the assistance of counsel or the benefit of a valid waiver in the presence of counsel, was admissible under the applicable constitutional standards.

Whether independent and corroborative evidence, apart from the extra-judicial confession (which in this case was the sole evidence against the accused), exists to establish the accused’s guilt beyond reasonable doubt.

Whether the accused’s claim of self-defense, as presented in his sworn statement, could be vindicated or was undermined by the forensic evidence and the circumstances surrounding the altercation.