People v. Capulong
REITERATIONFacts
The Antecedents: On October 14, 1982, a buy-bust operation was conducted by the Constabulary Anti-Narcotics Unit (CANU) in Santissima Cruz, Santa Cruz, Laguna, targeting Danilo B. Capulong, alleged to be the number one pusher of marijuana in the area. An informant, Larry Estacio, was instructed to pose as a buyer. Estacio approached Capulong and agreed to sell six (6) small transparent plastic bags of dried marijuana leaves for P50.00. The transaction was witnessed by the CANU team, and immediately after Capulong received the marked money, he was arrested. Bernardo Paynaganan, who was with Capulong, was also apprehended and found with one stick of marijuana. Capulong was brought to headquarters, investigated, and executed an extrajudicial confession admitting guilt. Laboratory examination confirmed the seized leaves were marijuana. Procedural History: The Regional Trial Court, Branch XXVI, Santa Cruz, Laguna, found Danilo B. Capulong guilty beyond reasonable doubt of violating Section 4, Article II of Republic Act 6425 (Dangerous Drugs Act of 1972, as amended). He was sentenced to life imprisonment, a fine of P20,000.00, and to pay costs. The court rejected Capulong's defense, which alleged he was with Bernardo Paynaganan watching a basketball game when the informant, Larry Estacio, approached him. Capulong claimed Estacio, who was drunk, offered to buy marijuana, was refused, but returned with marijuana, gave a stick to Paynaganan, and left. Estacio later returned with CANU officials who arrested Capulong and Paynaganan. Capulong also alleged maltreatment during investigation, forcing him to sign a confession, and that his jewelry, shoes, and lighter were taken by an investigator. The Petition: The accused, Danilo B. Capulong, appealed the decision of the Regional Trial Court, raising issues concerning the admissibility of his extrajudicial confession due to alleged coercion and the credibility of witnesses.
Issue(s)
Whether the extrajudicial confession of the appellant is admissible in light of the alleged force, duress, and intimidation attending its execution. Whether the trial court erred in giving credence to the prosecution's evidence and rejecting the defense's evidence, particularly concerning the credibility of witnesses.
Ruling
The appeal is DISMISSED. The decision of the Regional Trial Court finding the accused guilty beyond reasonable doubt of violating Section 4, Article II of Republic Act 6425 is AFFIRMED.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court held that the issue of coercion surrounding the extrajudicial confession had become academic due to the provisions of the 1987 Constitution. Article III, Section 12 specifically states that the right to counsel cannot be waived except in writing and in the presence of counsel. Therefore, even if the confession were truthful and voluntarily given, its admission into evidence would be barred because it was made without the assistance of counsel. This ruling aligns with the pronouncements in People v. Benigno Pineda y Dimatulac. The Court emphasized that the constitutional safeguard is absolute, rendering the confession inadmissible regardless of the absence of coercion or its voluntary nature. On the credibility of witnesses and sufficiency of evidence: The Court affirmed the trial court's appreciation of the evidence, giving high respect to its findings as it was in the best position to observe the witnesses' demeanor. The accused was caught in flagrante delicto during a legitimate buy-bust operation conducted by CANU officers. The three CANU officers were eyewitnesses to the transaction, and their testimonies were given credence, as law enforcers are presumed to have regularly performed their duties in the absence of contrary proof. The Court found no reason to depart from the trial court's conclusion that the guilt of the accused was proven beyond reasonable doubt. The defense's allegations of extortion were not given credence, as the trial court reasoned that the existence of a case to be fixed would be a prerequisite for extortion, thus implicitly admitting the commission of a crime. The Court also noted that the delays in filing the complaint and submitting evidence were not sufficiently explained to support the extortion claim. The non-presentation of the informant, Larry Estacio, was deemed not fatal to the prosecution's case, as his testimony would have been merely corroborative and cumulative.
Main Doctrine
An extrajudicial confession made without the assistance of counsel is inadmissible in evidence, even if voluntarily given, pursuant to Article III, Section 12 of the 1987 Constitution. The guilt of an accused caught in flagrante delicto in a buy-bust operation, supported by the testimonies of law enforcers, is sufficient for conviction.