G.R. No. L-12343 - Luneta Motor Co. vs. Lopez

Case Summary (G.R. No. L-12343)

Key Dates and Procedural Posture

Interrogation and written waiver: July 18, 1973. Information for murder filed by the Provincial Fiscal of Bulacan: September 14, 1973 (Criminal Case No. 146-V-73). Arraignment: October 5, 1973 (accused pleaded not guilty). At trial the prosecution presented six witnesses; on June 3, 1974, Corporal Roca was presented to identify the accused’s written statement and alleged waiver. Respondent judge sustained defense objections to the use of the extrajudicial statement; the prosecution then filed this certiorari petition challenging the judge’s ruling. Decision by the Supreme Court: January 17, 1980.

Factual Background of the Interrogation and Alleged Waiver

On July 18, 1973, police investigators took a written statement from the accused. Corporal Roca allegedly informed Yupo in Tagalog that he was under investigation, that he had the right to remain silent and to counsel, and that anything he said could be used against him, then asked whether Yupo would narrate; Yupo replied “Opo.” A one‑page written form was produced, reflecting that Yupo was informed and nevertheless gave a statement; the form bore signatures allegedly of Yupo, Corporal Roca, and Roberto Sales and a purported certification by Teresita M. Tecson, but the record lacked clarity as to the date of notarization, the signatory’s authority, and the original signature’s legibility.

Issue Presented

Whether an extrajudicial confession obtained during custodial police interrogation without the presence of counsel is admissible, and whether the constitutional right to counsel during custodial interrogation (and the concomitant right to be informed of that right) may be validly waived — and if so, whether the alleged waiver in this record was voluntary, knowing and intelligent.

Ruling and Disposition

The Supreme Court (majority) dismissed the petition for certiorari and denied relief to the prosecution. The Court held that respondent Judge Caguioa did not commit grave abuse of discretion in sustaining the defense objection and excluding the extrajudicial confession; the trial court was ordered to resume the criminal trial forthwith. No costs were awarded.

Governing Legal Standard on Waiver and Application of Miranda

The Court reaffirmed that the Constitution incorporates the doctrine of Miranda: a person in custodial interrogation must be warned of the right to remain silent and the right to counsel, and any waiver of those rights must be voluntary, knowing, and intelligent. The Court cited Abriol v. Homeres and Johnson v. Zerbst for the proposition that constitutional rights can be waived but only with a clear, intelligent, and voluntary relinquishment. The Court therefore applied the Miranda standard to determine admissibility.

Majority’s Analysis of the Waiver Evidence

Applying the Miranda standard, the Court found the alleged waiver inadequate. The oral admonition and the single monosyllabic affirmative response (“Opo”) were perfunctory and insufficient to establish that Yupo intelligently and voluntarily waived his rights. The documentary evidence (a one-page form and an alleged certified copy) showed material defects: lack of clarity as to certification date and authority, illegible signatures, and absence of an original signature produced to the Court. The prosecution did not demonstrate the required clear, informed, and voluntary waiver.

Consideration of Language, Age, and Comprehension

The Court placed considerable weight on Yupo’s youth (nineteen) and Visayan native background. The interrogation and the warning were conducted in Tagalog without any showing that Yupo was sufficiently familiar with Tagalog to comprehend fully the legal content of the warning. Citing People v. Bacong, the Court warned against imputing comprehension of legal rights when questioning is conducted in a language the accused does not adequately understand. These circumstances further undermined any claim that waiver was intelligent and voluntary.

Constitutional Import and the Trial Judge’s Discretion

Because the Constitution expressly declares that any confession obtained in violation of the provision shall be inadmissible, the majority concluded the trial judge correctly applied the “plain dictate” of the constitutional provision in excluding the confession. The Court emphasized that procedural formulas cannot substitute for real protection of constitutional safeguards; where the record does not demonstrate a valid waiver, exclusion is required.

Dissent (Justice Aquino)

Justice Aquino dissented. He contended that the judge ruled prematurely by excluding the confession at the stage of mere identification rather than at the time the confession was formally offered in evidence; the appropriate practice is to permit the investigator (Corporal Roca) to testify as to the circumstances and voluntariness so the court could then determine admissibility. Drawing on Miranda, Aquino asserted that the right to counsel may be waived if the waiver is voluntary, knowing, and intelligent, and that the prosecution should have been allowed to present Roca’s testimony to establish compliance. He would have reversed the judge’s ruling and allowed the prosecution to

Case Syllabus (G.R. No. L-12343)

Procedural Posture and Citation

Reporter citation: 180 Phil. 1; 76 OG No. 39, 7149 (September 29, 1980).
Case docket and internal citation: G.R. No. L-38975; Decision promulgated January 17, 1980; opinion announced En Banc.
Nature of proceeding: Petition for certiorari filed by the People of the Philippines challenging a ruling of respondent Judge Eduardo P. Caguioa.
Point of attack: Respondent Judge sustained defense objection to the admissibility of an extrajudicial statement and alleged waiver of rights by accused Paquito Yupo, obtained during police interrogation.
Disposition: Petition for certiorari dismissed; trial ordered to resume forthwith; no costs.
Bench composition on majority opinion: Fernando, C.J., with Makasiar, Concepcion, Jr., Santos, Fernandez, Guerrero, Abad Santos, De Castro, and Melencio-Herrera, JJ., concurring.
Separate opinions: Barredo, J., concurs in a separate opinion; Teehankee, J., concurs in the result; Antonio, J., concurs with Justice Aquino; Aquino, J., files a dissent (attached to decision).
Relevant dates in case record: Information filed September 14, 1973; interrogation and alleged waiver/statement dated July 18, 1973; arraignment October 5, 1973; prosecution witness identified statements at hearing June 3, 1974.

Title, Parties and Lower-Court Assignment

Petitioner: The People of the Philippines (Provincial Fiscal of Bulacan filed the information for murder).
Respondents: Hon. Eduardo P. Caguioa (Judge, Court of First Instance of Bulacan, Branch VIII) and Paquito Yupo y Gonzales (accused/private respondent).
Case docketed as Criminal Case No. 146-V-73 and, after raffle, assigned to Branch VIII presided by respondent Judge.
Arraignment: Accused pleaded not guilty on October 5, 1973.

Factual Background as Presented by the Record

Accused Paquito Yupo, nineteen years old, a native of San Policarpio, Eastern Samar, was interrogated by Meycauayan police on July 18, 1973.
On July 18, 1973, a written document was produced: a one-page statement (extrajudicial confession/statement) and a written waiver purportedly signed by Paquito Yupo, Corporal Conrado B. Roca, and Roberto Sales; certified as a true copy by Teresita M. Tecson (signature illegible, connection to the Court not shown).
Corporal Conrado B. Roca identified the accused's statement and the alleged waiver when presented as a prosecution witness at the June 3, 1974 hearing.
The prosecution’s trial presentation included six witnesses: Miguel Tribol (father of the deceased), Lydia Begnotia (common-law wife of the deceased, alleged recipient of an ante mortem statement), a medico-legal officer (autopsy), two policemen, and Gracia Santos Wage.
The prosecution relied on the extrajudicial statement and alleged waiver as evidence forming the basis for the information for murder.

Government’s Petition and Claim of Grave Abuse

The People sought certiorari to challenge the respondent Judge’s ruling excluding the extrajudicial confession and sustaining defense objection.
The petition accused respondent Judge Caguioa of grave abuse of discretion in excluding the statement on the ground of unconstitutional procedure and asserting that the right to counsel could not be waived.
The People argued that a valid waiver had been given by the accused and that Magtoto v. Manguera was not applicable (noting the interrogation post-dated the current Constitution).

Constitutional Provision Invoked

Article IV, Section 20 (as quoted in the opinion):
"No person shall be compelled to be a witness against himself. Any person under investigation for the commission of an offense shall have the right to remain silent and to counsel, and to be informed of such right. No force, violence, threat, intimidation, or any other means which vitiates the free will shall be used against him. Any confession obtained in violation of this section shall be inadmissible in evidence."
The majority treats this constitutional provision as adopting Miranda-type protections; the provision supplies the legal standard for admissibility of confessions and waivers.

Central Legal Issues Framed by the Court

Whether respondent Judge Caguioa committed grave abuse of discretion by excluding the extrajudicial confession and by holding that the constitutional right to counsel during custodial interrogation cannot be waived.
Whether the alleged waiver of the right to remain silent and to counsel by Paquito Yupo was freely, voluntarily and intelligently given, thus rendering the extrajudicial statement admissible.
Whether certiorari was the appropriate remedy to challenge respondent Judge’s ruling at the stage filed.

Majority Holding (Chief Justice Fernando)

Certiorari does not lie; the petition must be dismissed.
The trial court did not improvidently exercise authority in sustaining the defense objection and excluding the confession, given the constitutional mandate.
The alleged waiver was not shown to have been given freely and voluntarily; the questioning by the police was perfunctory and the record did not establish a clear, intelligent waiver.
The ruling that the statement was inadmissible was consonant with Section 20 of the Constitution and the Miranda doctrine as adopted by that section.

Rationale and Legal Reasoning of the Majority

The Constitution’s Section 20 adopted Miranda-like safeguards requiring that persons under custodial interrogation be informed of the right to remain silent and to counsel and that any confession obtained in violation is inadmissible.
A waiver is permissible only if made intelligently and voluntarily; Abriol v. Homeres (1949) and Johnson v. Zerbst were cited as precedent for the intelligent-voluntary-waiver standard.
The Miranda decision (Miranda v. Arizona) was quoted at length to articulate the required warnings and the standard that a waiver must be "voluntary, knowingly and intelligently."
Application of these principles to the case facts: the police’ perfunctory recitation of rights and the monosyllabic response ("Opo") were insufficient to prove intelligence and voluntariness of waiver.
Critical doubts: the accused was a nineteen-year-old native of Samar interrogated extensively in Tagalog without any showing his command of Tagalog was adequate for full comprehension of the warnings and queries.
Documentary irregularities: the annexed waiver (Annex C) lacked certain details (the date when subscribed and sworn before Municipal Judge Mariano Mendieta not specified); Teresita M. Tecson’s certification lacked proof of connection to the court and bore only illegible initials.
The single-page purported corroborative statement reproduced in full raised further doubt because it appeared to be an attempt to simulate an intelligent waiver but instead affirmed the same infirmities.
People v. Bacong was invoked as a caution against imputing comprehension to an accused when the language used is not one with which he is familiar.
Given these factual and documentary defects, the majority concluded the waiver was not established, rendering the confession inadmissible as required by the Constitution.
The lower court acted within the "plain dictate of the Constitution" in excluding the confession.

Factual Findings Applied to Legal Standard

The question orally posed by Corporal Roca (Annex B) read to the accused — in Tagalog — requested acknowledgment of rights and asked: "magsasalaysay ka pa rin ba?" to whic