Case Summary (G.R. No. L-63861)
Charges and Initial Findings
Florencio Poyos was found guilty of murder, with aggravating circumstances including treachery and evident premeditation, and was ultimately sentenced to death. The cause of death was originally certified to be a cerebral hemorrhage, but the actual cause of death was clarified later through an autopsy that revealed a contusion compatible with severe hemorrhage.
The Extrajudicial Confession
The case primarily hinged on an extrajudicial confession made by Florencio Poyos, which was taken following an investigation by police officer Pat. Ranulfo Tabudlong. The confession was signed before Clerk of Court Maria Cleofe L. Clarin, who testified that it was signed voluntarily. However, Poyos later repudiated the confession, claiming coercion and alleging additions were made to his statement.
Defense Testimony
Florencio Poyos testified that he did not commit the crime and linked his visit to Paula Angoy's residence to helping after she had already died. He refuted that he had made a confession regarding the circumstances of her death and stressed that it was extracted under duress, stating he was afraid of police threats during the interrogation process.
Prosecution's Argument
The prosecution maintained that the confession was valid, arguing it satisfied constitutional requirements and that Poyos had waived his right to counsel before his interrogation. They claimed that he was informed of his rights and voluntarily agreed to continue without an attorney.
Legal Framework and Constitutional Rights
The admissibility of the extrajudicial confession was evaluated under Article IV, Section 20, of the 1973 Constitution, which protects individuals from self-incrimination and mandates their right to counsel during custodial investigation. The decision referenced various U.S. Supreme Court precedents aimed at safeguarding these rights against police coercion.
Examination of Waiver of Counsel
The court scrutinized whether the waiver of the right to counsel was valid. The questioning phrased to evoke consent indicated a potential lack of clarity, particularly as the waiver was conditioned on the absence of a lawyer "for the moment," questioning its permanence.
Flaws in the Confession
In addition to the absence of counsel during the interrogation, the court noted inconsistencies in the confession, which raised suspicions about its validity. The language used in the confession contradicted Florencio Poyos' educational background, suggesting that it may have been prepared by the police rather than originating from him.
Conduct Foll
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Case Overview
- The case addresses the admissibility of an extrajudicial confession made by the accused-appellant, Florencio Poyos, which he later repudiated during the trial.
- The legal question centers on the interpretation of Article IV, Section 20, of the 1973 Constitution regarding the rights of individuals under investigation.
Facts of the Case
- Incident: The accused, Sabas Poyos, Liliosa Poyos, and Florencio Poyos, were implicated in the murder of Paula Angoy, a 77-year-old woman, on August 12, 1980, in Balilihan, Bohol.
- Murder Details: Paula Angoy was allegedly killed by being struck on the neck with a piece of wood.
- Trial Dynamics: Only Florencio Poyos was tried since the other two co-accused absconded.
- Verdict: Florencio was found guilty of murder with multiple aggravating circumstances and sentenced to death.
Medical Evidence
- Initial Certification: The cause of death was initially certified as cerebral hemorrhage based solely on information from Sabas Poyos.
- Autopsy Findings: After an autopsy a year later, a contusion consistent with the cause of death was discovered, leading to further investigation.
Confession Details
- Interrogation: Following the autopsy, police investigator Pat. Ranulfo Tabudlong interrogated Florencio Poyos, who provided an extrajudicial confession.
- Witness Testimony: Clerk of Court Maria Cleofe L. Clarin testified that the confession was made voluntarily and signed in her presence.
Defense Claims
- Denial of Charges: Florencio Poyos denied the murder allegations, asserting that Paula was already dead when he arr