Sampaga v. People
REITERATIONFacts
The Antecedents: Angel Sampaga y de los Reyes was charged with Homicide for allegedly stabbing and killing Marciano Soria y Posedia on April 7, 1976, in Quezon City. The incident occurred after a drinking spree at Sampaga's residence, during which Sampaga and Soria had a heated argument. Two witnesses left the scene before the stabbing. Marciano Soria died at the hospital from a stab wound. Procedural History: The trial court found Angel Sampaga guilty beyond reasonable doubt of homicide and sentenced him to an indeterminate penalty. The Court of Appeals affirmed the trial court's findings. The Petition: The case reached the Supreme Court on appeal, primarily questioning the admissibility of Sampaga's extra-judicial confession obtained during custodial investigation.
Issue(s)
Whether the extra-judicial confession of the petitioner is admissible in evidence. Whether the petitioner is entitled to acquittal due to the alleged violation of his constitutional rights during custodial investigation.
Ruling
The Supreme Court REVERSED AND SET ASIDE the decision of the Court of Appeals, ACQUITTING Angel Sampaga y De Los Reyes. Costs de officio.
Ratio Decidendi
On the admissibility of the extra-judicial confession: The Court held that while petitioner Angel Sampaga was informed of his constitutional rights to remain silent and to counsel, his extra-judicial confession was obtained without the presence and assistance of counsel. Applying the principles laid down in People vs. Dacoycoy, People vs. Galit, and Morales vs. Ponce Enrile, the Court ruled that a waiver of the right to counsel during custodial investigation must be made in the presence and with the assistance of counsel to be valid. Since Sampaga's confession was obtained in violation of this right, it was inadmissible in evidence. The Court noted that the 1973 Constitution, under which the confession was taken, merely provided the right to counsel, unlike the 1987 Constitution which specifies the manner of its exercise. However, the retroactive application of the Galit doctrine to confessions obtained prior to April 26, 1983, meant that the confession here was inadmissible. On the entitlement to acquittal: The Court found that the prosecution's case relied solely on the inadmissible extra-judicial confession of the petitioner. While the petitioner admitted the killing and even pointed to the weapon, the Court, in light of the ruling in People vs. Marcos P. Jimenez, held that any admission obtained during custodial interrogation without the assistance of counsel is inadmissible, even if voluntarily made or confirmed by external circumstances. Since there was no independent evidence apart from the uncounseled confession to prove Sampaga's guilt beyond reasonable doubt, he was entitled to acquittal.
Main Doctrine
An extra-judicial confession obtained during custodial investigation without the presence and assistance of counsel is inadmissible in evidence, even if the accused was informed of his rights, unless there is independent evidence of guilt.