In People v. Hijada, the Supreme Court underscored the importance of protecting the constitutional rights of individuals undergoing custodial investigation. The Court ruled that an extrajudicial confession obtained without the presence of counsel is inadmissible as evidence. This decision reaffirms the principle that the right to counsel is paramount during custodial investigations, ensuring that the accused is fully aware of their rights and is protected from self-incrimination.

The Price of Silence: Can Uncounselled Confessions Condemn?

Ricky Hijada, Danilo Alcera, and Rodelio Villamor were charged with robbery with multiple homicide for the deaths of Filonila Tupaz, Filomena Garcia, and Rosemarie Diaz. The prosecution’s case hinged significantly on Danilo Alcera’s extrajudicial confession, which implicated himself and his co-accused. However, this confession was obtained without the assistance of counsel, raising serious questions about its admissibility in court. The central legal question became: Can a confession obtained without legal counsel be used to convict someone, even if other evidence exists?

The Supreme Court meticulously examined the circumstances surrounding Danilo Alcera’s confession, emphasizing the constitutional right to counsel during custodial investigations, as outlined in Section 12(1) of Article III of the Constitution:

Sec. 12 (1) Any person under investigation for the commission of an offense shall have the right to be informed of his right to remain silent and to have competent and independent counsel preferably of his own choice. If the person cannot afford the services of counsel, he must be provided with one. These rights cannot be waived except in writing and in the presence of counsel.

Building on this principle, the Court emphasized that when an individual is in custody and treated as a suspect, they are entitled to these constitutional rights. Although Danilo Alcera signed a waiver of these rights, the police admitted that this waiver was not made in the presence of counsel. This crucial detail rendered the waiver invalid and, consequently, the confession inadmissible as evidence.

The Court distinguished this case from others where verbal admissions were made to private individuals. In those cases, the admissions were not obtained through formal police interrogation and were therefore not subject to the same constitutional protections. Here, the written extrajudicial confession, elicited under police interrogation, demanded strict adherence to constitutional safeguards. However, other pieces of evidence like recovered stolen items can be admitted in Court.

Appellants argued that their arrest and subsequent searches were illegal due to the lack of a valid warrant. Despite the procedural lapse acknowledged by the police, the Court noted that the appellants failed to raise this objection before their arraignment. According to established jurisprudence, any objection to an arrest or the court’s jurisdiction over the accused must be made before arraignment; otherwise, it is deemed waived. This procedural misstep barred the appellants from challenging the admissibility of evidence seized during the searches incident to their arrest.

Focusing on the available circumstantial evidence, the Court outlined the conditions for its sufficiency in securing a conviction. More specifically, the facts from which the inferences are derived must be proven, and the combination of all the circumstances must lead to a conviction beyond reasonable doubt. The trial court had identified several established facts, including the appellants’ prior planning of the robbery, their presence at the crime scene on the day of the incident, Ricky’s blood-stained shirt, and the recovery of stolen items from their possession.

Despite the appellants’ attempts to discredit the prosecution witnesses, the Court reiterated that the trial court’s findings on credibility are generally respected, absent any clear error or abuse of discretion. Furthermore, the defense of alibi was dismissed, as the appellants were positively identified at the crime scene, negating their claims of being elsewhere. Though the elements of robbery with homicide were present, the Court revised the penalty of death originally imposed by the trial court. The Court stated that since the crime was committed in 1992 before Republic Act No. 7695 which reimposed the death penalty took effect, the death penalty could not be imposed due to constitutional restrictions.

Ultimately, the Supreme Court found the appellants guilty of robbery with homicide, underscoring that it did not matter how many victims are killed, it is still considered one crime only. But due to the period when the crime was committed, the proper penalty was reclusion perpetua, along with civil indemnity and moral damages to the victims’ heirs.

FAQs

What was the key issue in this case?	The key issue was whether an extrajudicial confession obtained without the presence of counsel is admissible as evidence against the accused.
Why was Danilo Alcera’s confession deemed inadmissible?	Danilo Alcera’s confession was deemed inadmissible because he waived his right to counsel without the presence of a lawyer, violating his constitutional rights.
What is the significance of Section 12(1) of Article III of the Constitution?	Section 12(1) of Article III guarantees the right to counsel during custodial investigations, protecting individuals from self-incrimination.
Can an accused person waive their right to counsel?	Yes, an accused person can waive their right to counsel, but this waiver must be in writing and made in the presence of counsel.
What role did circumstantial evidence play in this case?	Circumstantial evidence, such as the appellants’ presence at the crime scene and possession of stolen items, was crucial in establishing their guilt.
Why couldn’t the police’s procedural lapses be challenged?	Because the appellants did not challenge the validity of their arrest or the search before the arraignment, they waived their right to do so.
What is the penalty for the crime of robbery with homicide?	The crime of robbery with homicide is punishable by reclusion perpetua to death, though the imposition of the death penalty may vary based on the date when the crime was committed.
Why was the death penalty not imposed in this case?	Since the crime was committed on September 14, 1992, prior to the effectivity of Republic Act No. 7695, the death penalty was not imposed.
What civil liabilities were imposed on the appellants?	The appellants were ordered to pay civil indemnity and moral damages to the heirs of the victims.

The People v. Hijada case is a reminder of the judiciary’s dedication to defending constitutional rights during criminal proceedings. It emphasizes that no conviction, no matter how compelling the evidence, may override the fundamental safeguards ensuring fairness and justice for all. In all cases, the constitutional rights of the accused take center stage.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Hijada, G.R. No. 123696, March 11, 2004