Title
People vs. Artellero
Case
G.R. No. 129211
Decision Date
Oct 2, 2000
A security guard was found dead in a bank; two workers were convicted based on circumstantial evidence and an inadmissible confession. The Supreme Court acquitted both, citing insufficient evidence and constitutional violations.
robbery
murder
constitutional rights

Case Summary (G.R. No. 129211)

Factual Background

On October 11, 1991, the lifeless body of Ramon Matias, a bank security guard, was discovered inside the Far East Bank and Trust Company branch in Sta. Cruz, Manila. The victim was hogtied with a nylon cord and bore thirty-two stab wounds; the premises were in disarray and the emergency exit vault showed chisel marks. Three .38-caliber revolvers and five 12-gauge shotguns were reported missing. Police investigators questioned bank employees and, during a follow-up, learned of on-going construction on the upper floors where appellant and Rodriguez worked and had after-hours access. Police proceeded to the construction barracks, observed appellant on the ground floor and Rodriguez packing on the third floor, and noted a pair of worn maong pants with reddish stains on appellant’s bed and reddish stains on Rodriguez’s shirt. The clothes were seized and submitted to the NBI for analysis.

Arrest, Confession, and Forensic Findings

Appellant and Rodriguez were arrested on October 11, 1991, and detained at the police station. On October 15, 1991, Rodriguez executed an extrajudicial confession implicating himself, appellant, and others in the killing; Atty. Procopio Lao III of the Public Attorney’s Office assisted Rodriguez and testified that he conferred with him for about ten minutes prior to execution of the sworn statement. The NBI chemistry supervisor testified that the reddish stains on Rodriguez’s pants and shirt were positive for type O human blood, which matched Rodriguez’s blood type. The PNP medico-legal report established cause of death as cardio-respiratory arrest due to shock and hemorrhage secondary to multiple stab wounds.

Trial Court Proceedings and Judgment

Appellant and Rodriguez pleaded not guilty at arraignment and were tried before the Regional Trial Court, Manila, Branch 29. The prosecution presented police officers, a PAO counsel, and an NBI chemistry supervisor, together with documentary and physical evidence including Rodriguez’s sworn statement, the maong pants and shirt, the medico-legal report, and other reports. Appellant filed a demurrer to the evidence, which the trial court denied. The defense presented the bank manager, appellant, and Rodriguez, each denying participation in the killing and alleging improprieties in police conduct. The trial court found both accused guilty not of robbery with homicide but of murder under Art. 248 of the Revised Penal Code, sentenced each to reclusion perpetua, imposed civil indemnity of P50,000.00 to the heirs of the victim, and dismissed the robbery charge.

The Parties’ Contentions on Appeal

Appellant contended that the trial court erred in: (1) giving credence to Rodriguez’s extrajudicial confession as circumstantial proof of conspiracy and of appellant’s participation; (2) attributing the maong pants stained with type O blood to appellant and treating that as circumstantial proof; (3) treating the fact that appellant and Rodriguez worked and slept together as sufficient circumstantial evidence of guilt; and (4) convicting for a more serious offense than that charged in the Information. The Office of the Solicitor General filed a Manifestation and Motion in Lieu of Appellee’s Brief asserting that the trial court erred in admitting Rodriguez’s extrajudicial confession against appellant and, assuming admissibility, that no independent evidence established conspiracy; that the blood-stain evidence lacked probative value because the victim’s blood type was not compared; and that the Information did not allege circumstances qualifying the killing as murder.

Issues Presented

The principal issues were whether Rodriguez’s extrajudicial confession was admissible against Rodriguez and against appellant; whether independent evidence aside from the confession established conspiracy; whether the blood-stained clothing linked appellant to the crime with any probative value; and whether the trial court properly converted the charge to murder.

Ruling of the Supreme Court

The Supreme Court reversed the conviction and ordered the acquittal and immediate release of appellant Larry Artellero y Rico and co-accused Wilfredo Rodriguez y Culo. The Court held that Rodriguez’s extrajudicial confession was inadmissible because it was obtained in violation of Art. III, Sec. 12, 1987 Constitution, principally for lack of competent and independent counsel throughout the period of custodial investigation. With the confession excluded, the Court found no other evidence sufficient to sustain a conviction of murder against either accused. The Court also directed the Director of Prisons to inform the Court of compliance and imposed no costs.

Legal Basis and Reasoning

The Court applied the constitutional protections of Art. III, Sec. 12, 1987 Constitution, which guarantees the right of a person under investigation to be informed of the right to remain silent and to have competent and independent counsel preferably of his own choice, and provides that any confession obtained in violation of that section is inadmissible. The Court treated the moment of arrest and custody on October 11, 1991, as the commencement of custodial investigation, citing precedent such as People v. Bolanos, and observed that Rodriguez and appellant were deprived of counsel for approximately four days. The Court emphasized the rule in People v. De la Cruz, People v. Compil, People v. Olivarez, Jr., and People v. Cabiles that an accused must continuously have counsel assisting from the start of custodial interrogation and that a confession, however truthful, is inadmissible if obtained without the assistance of counsel.

The Court further analyzed evidentiary rules governing use of an extrajudicial confession against co-accused. It noted that Section 33 of Rule 130 of the Rules of Court limits the admissibility of an extrajudicial confession to the confessant, and that Section 30 of Rule 130 requires independent evidence, aside

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