People v. Dacoycoy
REITERATIONFacts
1. The Antecedents: Angeles Latoga y Lagco and Danilo Dacoycoy, along with an unapprehended individual known as "John Doe @ Sonny," were charged in July 1982 with the special complex crime of robbery with homicide. The victim was Edilberto Lisondra y Benitez, and the stolen items, consisting of cash and a watch, were valued at P600.00. The Regional Trial Court of Quezon City found Latoga and Dacoycoy guilty beyond reasonable doubt and imposed the penalty of reclusion perpetua, along with civil indemnities to the victim's heirs and damages. 2. Procedural History: Following their conviction by the Regional Trial Court, both Angeles Latoga and Danilo Dacoycoy appealed their sentences. However, Danilo Dacoycoy subsequently filed a motion to withdraw his appeal, which was granted by the Supreme Court on September 23, 1987. This left only Angeles Latoga's appeal pending before the Court. The trial court's decision was based solely on the extrajudicial confessions of the accused, which they later repudiated, claiming they were obtained without the assistance of counsel. 3. The Petition: In his appeal, Angeles Latoga argued that the trial court erred in admitting his extrajudicial confession, Exhibit A, which was obtained without the assistance of counsel of his choice. He contended that this confession violated his constitutional rights as established in Morales v. Ponce Enrile. The Solicitor General argued that the Morales doctrine, which requires the presence of counsel for a valid waiver of rights during custodial investigation, should not apply retroactively to confessions made before its promulgation. However, the Supreme Court, citing subsequent rulings in People v. Galit and People v. Pecardal, held that the Morales doctrine, requiring counsel's assistance for a valid waiver, applied even to confessions made prior to April 26, 1983. Consequently, Latoga's confession was deemed inadmissible, leading to his acquittal.
Issue(s)
Whether the extrajudicial confession of appellant Angeles Latoga, obtained without the assistance of counsel, is admissible in evidence. Whether the doctrine laid down in Morales v. Ponce Enrile applies to confessions obtained prior to its promulgation.
Ruling
The judgment of the Trial Court is REVERSED AND SET ASIDE, and the appellant, Angeles Latoga y Lagco @ Ely and @ Angel, is AQUITTED, with costs de officio.
Ratio Decidendi
On Issue 1: The extrajudicial confession of appellant Angeles Latoga, Exhibit "A," was obtained without the assistance of counsel of his choice. The Court reiterated that under Section 20 of the Bill of Rights of the 1973 Constitution, any confession obtained in violation of the right to remain silent and to counsel shall be inadmissible in evidence. While the 1973 Constitution allowed waiver of these rights, subsequent rulings, including Morales v. Ponce Enrile, imposed the requirement that such waiver must be made in the presence and with the assistance of counsel. Since Latoga's confession was admittedly given without counsel, it should not have been admitted in evidence against him. On Issue 2: The doctrine requiring the assistance of counsel for a valid waiver of rights during custodial investigation, as laid down in Morales v. Ponce Enrile, applies retroactively to confessions obtained prior to April 26, 1983. The Court clarified that even before the effectivity of the 1987 Constitution, which explicitly requires waiver to be in writing and in the presence of counsel, the need for assistance of counsel as a prerequisite for according validity to a waiver was already established. Cases like People v. Galit and People v. Pecardal applied this principle to confessions made before April 26, 1983, and the Court saw no impediment to applying it in the present case. Therefore, the confession obtained from Latoga before the promulgation of Morales v. Ponce Enrile is inadmissible.
Main Doctrine
An extrajudicial confession obtained during custodial investigation without the assistance of counsel is inadmissible in evidence, even if the waiver of rights was made prior to the promulgation of the doctrine requiring such assistance, as the principle applies retroactively to confessions made before the doctrine was laid down.