Case Summary (G.R. No. 151286)
Key Dates
- November 29, 1996: The murder of Elva Ramos-Jacob takes place.
- April 1, 1997: Initial information charging DueAas with murder is filed.
- October 26, 2001: The Regional Trial Court (RTC) of Baler, Aurora, convicts DueAas of murder, imposing a death sentence.
- March 31, 2004: The decision is reviewed by the Supreme Court.
Applicable Law
This case references the 1987 Philippine Constitution, particularly Article III, Section 12, which outlines the rights of individuals under custodial investigation.
Summary of Facts
Catalino DueAas, Jr. was charged with the murder of Elva Ramos-Jacob. He was previously convicted of homicide in 1990 and was serving time in Iwahig Prison Farm when he escaped in 1995. On November 29, 1996, witnesses reported hearing gunshots, and DueAas was subsequently implicated in the murder after he was apprehended by police on December 18, 1996, following an unrelated incident.
The Confession and Legal Proceedings
During custodial investigation, DueAas confessed to the murder, asserting he was commissioned by another individual, Benny Poblete. His confession was written down and signed in the presence of a lawyer, Atty. Josefina S. Angara. However, DueAas later claimed that he was coerced into confessing due to physical abuse by police, which he denied discussing with his lawyer at the time.
Trial Court's Ruling
The RTC convicted DueAas based largely on his extrajudicial confession, finding it voluntarily given despite his claims of coercion. He was sentenced to death, and the decision emphasized his admission of guilt and the consistency of details in his confession as indicative of its voluntariness.
Appeal and Arguments
DueAas filed an automatic appeal, arguing that his confession was obtained through force and intimidation, violating his constitutional rights. The Office of the Solicitor General (OSG) acknowledged the potential involuntariness of the confession and supported DueAas's argument for acquittal.
Supreme Court's Analysis
The Supreme Court determined that the extrajudicial confession was inadmissible. The Court highlighted violations of DueAas's rights under the 1987 Constitution, particularly
...continue readingCase Syllabus (G.R. No. 151286)
Case Overview
- The case is an automatic review of the decision dated October 26, 2001, by the Regional Trial Court (RTC) of Baler, Aurora, Branch 96.
- Catalino DueAas, Jr. was found guilty beyond reasonable doubt of murder qualified by evident premeditation, with the aggravating circumstance of recidivism.
- DueAas was sentenced to death.
Factual Background
- On April 1, 1997, Provincial Prosecutor Charlaw W. Ronquillo filed an information charging DueAas with murder.
- The incident occurred on November 29, 1996, in Gabgab Buhangin, Baler, Aurora, where DueAas fatally shot Elva Ramos-Jacob (also known as Elving Jacob) with a .38 caliber revolver.
- Prior to this, DueAas had a history of conviction for homicide and had escaped from Iwahig Prison Farm.
Incident Details
- At approximately 8:00 AM on the day of the incident, a witness, Cesar Friginal, heard gunshots while working in his rice field and later discovered the deceased woman, identified as his cousin.
- The autopsy conducted by Dr. Nenita S. Hernandez revealed gunshot wounds to the head as the cause of death.
Arrest and Confession
- DueAas was arrested on December 18, 1996, after attempting to enter the home of a man named Benny Poblete.
- Following his arrest, DueAas allegedly confessed to the murder on December 23, 1996, during an interrogation.
- His confession deta