People v. Hernandez
REITERATIONFacts
The Antecedents: Felicisimo Hernandez and Carlos Imperial, both beauticians, were placed under surveillance by the Integrated National Police of Carmona, Cavite, on suspicion of involvement in the distribution and sale of marijuana. They were arrested on July 20, 1984. Marked money was found in Hernandez's possession, and marijuana leaves in a matchbox were found with Rizaldy Angcaya, an informer who allegedly purchased them from Hernandez. Both accused admitted in sworn statements to selling marijuana to Angcaya. Examination confirmed the dried leaves were marijuana. Procedural History: An information was filed charging Hernandez and Imperial with violation of Section 4 of Republic Act No. 6425 (The Dangerous Drugs Act of 1972). The Regional Trial Court of Bacoor, Cavite, convicted both accused on October 15, 1985, sentencing them to life imprisonment, a P20,000.00 fine, and costs. The Petition: Only Carlos Imperial appealed, assigning as errors the admission of his extrajudicial confession allegedly obtained in violation of his constitutional rights, and the failure to prove his guilt beyond reasonable doubt.
Issue(s)
Whether the extrajudicial confession of the accused-appellant was admissible in evidence. Whether the guilt of the accused-appellant was proved beyond reasonable doubt.
Ruling
The judgment of the trial court is REVERSED and SET ASIDE. Accused-appellant Carlos Imperial is ACQUITTED, with costs de oficio.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Court found that while the accused-appellant was informed of his constitutional rights to remain silent and to counsel, and he answered affirmatively when asked if he was waiving his right to counsel, this waiver was made without the assistance of counsel. The Court reiterated the clear rule that the right to counsel may be waived, but such waiver is not valid unless made with the assistance of counsel. Consequently, any statement obtained in violation of this procedure, including the extrajudicial confession of the appellant (Exhibit H), is inadmissible in evidence. The prosecution relied solely on this confession, and with its exclusion, the case against the appellant must fall. On whether the guilt of the accused-appellant was proved beyond reasonable doubt: The prosecution's case rested entirely on the extrajudicial confession of the appellant, which the Court has declared inadmissible. The informer, Rizaldy Angcaya, who allegedly accompanied the appellant and was present during the alleged sale, was not presented as a witness by the prosecution. Without the confession, there is no evidence to establish the guilt of the accused-appellant beyond reasonable doubt. Therefore, the conviction by the trial court cannot stand.
Main Doctrine
A waiver of the right to counsel during custodial investigation is invalid unless made with the assistance of counsel. Any confession obtained in violation of this procedure is inadmissible in evidence.