Magtoto v. Manguera
REITERATIONFacts
1. The Antecedents: These consolidated cases revolve around the admissibility of extrajudicial confessions obtained from individuals under investigation for criminal offenses. The core issue is the interpretation and application of Section 20, Article IV of the New Constitution, which mandates that individuals under investigation have the right to remain silent and to counsel, and that any confession obtained in violation of this right is inadmissible. The cases involve charges such as murder and robbery with homicide. 2. Procedural History: In G.R. Nos. L-37201-02 and L-37424, the lower courts admitted extrajudicial confessions obtained before the effectivity of the New Constitution, despite the accused not being informed of their right to counsel. Conversely, in G.R. No. L-38929, the lower court rejected confessions obtained before the New Constitution's effectivity, also on the grounds of the accused not being informed of their right to counsel. The Supreme Court is tasked with reviewing these conflicting rulings. 3. The Petition: The petitions, brought before the Supreme Court, primarily concern the retroactivity of the constitutional right to counsel during custodial interrogations, as established by Section 20, Article IV of the New Constitution. The petitioners in L-37201-02 and L-37424 seek to have confessions admitted, while the petitioner in L-38929 seeks to have confessions excluded. The central argument is whether confessions obtained prior to the New Constitution's effectivity, without informing the accused of their right to counsel, are admissible. The Court must determine if this new constitutional provision has retroactive application.
Issue(s)
Whether the right to be informed of the right to silence and to counsel under Section 20, Article IV of the 1973 Constitution should be given retroactive effect to cover extrajudicial confessions obtained before January 17, 1973.
Ruling
The petitions in G.R. Nos. L-37201-02 and G.R. No. L-37424 are denied, and the petition in G.R. No. L-38929 is granted. Consequently, all confessions involved in said cases are declared admissible in evidence.
Ratio Decidendi
On Issue 1: The Supreme Court held that the constitutional mandate in Section 20, Article IV of the 1973 Constitution must be applied prospectively. The Court reasoned that this provision granted a "new right" to persons under investigation—the right to be informed of the right to counsel—which did not exist under the 1935 Constitution or prior jurisprudence. Applying the ruling in People v. Jose, the Court reaffirmed that the Miranda rule from the United States was previously rejected in the Philippine jurisdiction. Since the right to be informed of counsel warnings did not exist at the time the confessions were executed (between 1968 and 1972), no right could have been violated to warrant the exclusion of the evidence. The Court further noted that giving the provision retroactive effect would have a "disastrous consequence" on the administration of justice, potentially leading to the mass acquittal of guilty individuals whose confessions were obtained in accordance with the rules then in force. Finally, the Court clarified that Article 22 of the Revised Penal Code (RPC) regarding the retroactivity of penal laws is inapplicable because it refers to substantive laws, whereas the constitutional provision in question is essentially a procedural rule of evidence.
Main Doctrine
The right to counsel and to be informed of such right, as enshrined in Section 20, Article IV of the New Constitution, is prospective in effect and applies only to confessions obtained after the effectivity of the New Constitution on January 17, 1973. Confessions obtained before this date, even if the accused was not informed of his right to counsel, are admissible in evidence.