GAERLAN, J.
Facts
Aron Akil y Guamalon (Akil) was charged with Carnapping under Republic Act No. 10883. The private complainant, JR Belardo (Belardo), found his motorcycle missing and reviewed CCTV footage showing the perpetrator, whose face was obscured by a mask, cap, and sunglasses, wearing a yellow Fubu shirt. Eighteen days later, Akil was arrested for stealing a different motorcycle. Belardo subsequently went to the police station and identified Akil, based on the fact that Akil allegedly resembled the person in the CCTV footage and the police had retrieved clothing and accessories (red ball cap, yellow Fubu shirt, black mask, sling bag) said to belong to Akil. Belardo also claimed Akil confessed to the crime while detained. Akil denied the accusation, claiming the items were not his, and asserted that the alleged confession was uncounseled and thus inadmissible. The Regional Trial Court (RTC) and the Court of Appeals (CA) found Akil guilty based on circumstantial evidence.
Issues
- Whether the circumstantial evidence presented by the prosecution was sufficient to establish the identity of Akil as the perpetrator of the crime of Carnapping beyond reasonable doubt.
- Whether Akil’s extrajudicial confession, made to the private complainant while detained without the assistance of counsel, was admissible as evidence against him.
Ruling
“ACCORDINGLY, the appeal is GRANTED. The Decision dated August 30, 2022 of the Court of Appeals in CA-G.R. CR-HC No. 02496-MIN is REVERSED and SET ASIDE. For failure on the part of the prosecution to prove his guilt beyond reasonable doubt, accused-appellant Aron Akil y Guamalon is ACQUITTED of the crime charged in Criminal Case No. 5281-18. He is ORDERED IMMEDIATELY RELEASED from detention unless he is being detained for some other lawful cause”.
Essential Elements of Jurisprudence
The Supreme Court established the following controlling doctrines and legal principles:
- Requirement of Proof Beyond Reasonable Doubt: The quantum of proof required to sustain a conviction (proof beyond reasonable doubt) applies not only to the elements of the crime but also, primarily, to establishing the identity of the offender.
- Standards for Circumstantial Evidence: A conviction based solely on circumstantial evidence requires that the circumstances proven constitute an unbroken chain which leads to one fair and reasonable conclusion that points to the accused, to the exclusion of all others, as the guilty person.
- Unreliability of Suggestive Out-of-Court Identification (Show-up): Identification procedures, especially show-ups, must meet the totality of circumstances test. Belardo’s identification was highly dubitable because:
- It was a show-up conducted while Akil was already detained and singled out as the culprit, making the procedure “tainted with apparent suggestiveness”.
- Belardo was not an actual eyewitness and never saw the perpetrator’s face.
- An inference cannot be based on another inference (i.e., inferring guilt based on matching clothes where the CCTV footage was unauthenticated and testimony regarding the retrieval of the clothes was contradictory).
- Inadmissibility of Uncounseled Confession during Custodial Investigation:
- Custodial Investigation Defined: Custodial investigation begins when law enforcement officers initiate questioning after a person has been taken into custody or otherwise deprived of freedom, or when the investigation begins to focus on a particular suspect. Akil was under custodial investigation from the moment he was detained and singled out by the police.
- Circumvention of Rights: The rights guaranteed by Article III, Section 12(1) of the Constitution and Section 2 of Republic Act No. 7438 cannot be circumvented by police officers deliberately sending a private individual (the victim) to confront, question, and extract a confession from a detained suspect.
- Effect of Violation: An extrajudicial confession obtained in violation of the right to counsel and other rights during custodial investigation is inadmissible as evidence against the accused.
Sample Q&A
Question: Aron Akil was detained by police for theft and was subsequently confronted by the victim, Belardo, in the police station. Belardo, who was deliberately sent by the police, asked Akil about the stolen motorcycle, and Akil confessed to him. Can this extrajudicial confession be admitted as evidence against Akil during trial, even if Belardo is not a police officer?
Answer: No, the confession is inadmissible. When Akil was detained and singled out by the police for confrontation, he was already considered to be under custodial investigation. Although Akil confessed to a private individual (Belardo), the questioning was initiated and arranged by law enforcement officers, constituting an attempt to circumvent the constitutional safeguards. Therefore, the confession was obtained in violation of Akil’s right to competent and independent counsel as guaranteed by Article III, Section 12(1) of the 1987 Constitution. Furthermore, under Section 2(d) of Republic Act No. 7438, an extrajudicial confession made by a person under custodial investigation is inadmissible unless it is in writing, signed, and done in the presence of counsel (or upon a valid waiver in the presence of other authorized persons). Since Akil’s confession lacked these safeguards, it is void and cannot be used as a basis for conviction.
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