People v. Taruc
REITERATIONFacts
The Antecedents: The accused-appellant, Cirilo Taruc y Reyes, was charged with violating Section 4 of Republic Act No. 6425, as amended (Dangerous Drugs Act of 1972), for allegedly selling two matchboxes of dried marijuana fruiting tops to an informer of the Integrated National Police (INP) in Cabanatuan City on March 6, 1984. The prosecution presented testimonies of Patrolmen Feliciano Liguero and Enrico Campos, who claimed to have caught Taruc in flagranti delicto. A forensic chemist confirmed the contents of the matchboxes to be positive for marijuana. Taruc executed an extrajudicial confession admitting to selling marijuana, which was presented as Exhibit "B". Procedural History: The Regional Trial Court of Cabanatuan City, Branch XXIX, found Cirilo Taruc y Reyes guilty beyond reasonable doubt and sentenced him to reclusion perpetua, a fine of P20,000.00, and costs. The accused appealed this decision. The Petition: The accused-appellant raised two assignments of error: (I) the trial court erred in appreciating the alleged written confession (Exhibit "B") despite being procured through force, violence, and intimidation; and (II) the trial court erred in disregarding the defense's evidence despite its convincing presentation.
Issue(s)
Whether the extrajudicial confession of the accused-appellant is admissible in evidence. Whether the guilt of the accused-appellant was established beyond reasonable doubt, considering the credibility of the prosecution witnesses and the evidence presented. Whether the testimonies of the prosecution witnesses were credible and free from contradictions.
Ruling
The Supreme Court reversed and set aside the decision of the Regional Trial Court, acquitting the appellant on the ground of reasonable doubt. The Court found the extrajudicial confession inadmissible and the prosecution's evidence insufficient to establish guilt beyond reasonable doubt.
Ratio Decidendi
On the admissibility of the extrajudicial confession: The Supreme Court held that the extrajudicial confession (Exhibit "B") was inadmissible in evidence. The Court agreed with the Solicitor General that the investigator's questioning, followed by monosyllabic answers, did not satisfy the constitutional requirement of informing the accused of his rights. Citing People v. Nicandro, the Court emphasized that informing the accused of their rights requires transmitting meaningful information and explaining the effects in practical terms, not just a ceremonial recitation. Furthermore, the appellant claimed he was subjected to a "water treatment" and forced to sign the confession, a claim that, if true, would render the confession involuntary. The Court reiterated the principle that trial courts must carefully scrutinize confessions, especially when maltreatment is alleged, and any doubt as to voluntariness must lead to its rejection in toto. On whether the guilt was established beyond reasonable doubt, considering the credibility of the prosecution witnesses and the evidence presented: The Supreme Court found that if the extrajudicial confession were disregarded, the prosecution had no other evidence to sustain a finding of guilt beyond reasonable doubt. The Court noted that the testimonies of the arresting officers, Patrolmen Liguero and Campos, were replete with contradictions and inaccuracies, creating doubt about the circumstances of the arrest and the alleged sale. The presumption that official duty was regularly performed cannot prevail over the constitutional presumption of innocence when such doubts exist. The Court also considered the credibility of the prosecution witnesses in determining whether guilt was established beyond a reasonable doubt. On the credibility of prosecution witnesses: The Court found significant misapprehensions of facts, inconsistencies, and discrepancies in the prosecution's evidence. Patrolman Liguero's testimony was unclear regarding the identity of the informant and whether he was present during the alleged sale, even contradicting himself on whether the informant was Patrolman Campos. Furthermore, Liguero's and Campos's testimonies conflicted on who physically possessed and took the matchboxes from the appellant during the arrest. Patrolman Campos himself admitted he was not certain of the contents of the matchboxes and relied on the informer's representation, undermining the certainty of the alleged sale. The Court also noted that the inculpatory facts were capable of an explanation consistent with the accused's innocence, thus failing the test of moral certainty required for conviction.
Main Doctrine
An extrajudicial confession procured through force, violence, or intimidation, or where the accused was not properly informed of his constitutional rights, is inadmissible in evidence. The presumption of innocence of the accused prevails over the presumption that official duty was regularly performed when doubt exists regarding the voluntariness of a confession or the circumstances of an arrest.