People Vs Rodriguez Camat - Confession

CONFESSIONS
People v. Rodriguez, G.R. No. 112262, April 2, 1996-Panelo
Facts:
About 9:00 o'clock in the evening of September 1, 1985, Nelson Sinoy and Gonzalo
Penalver, both members of the Philippine Marines stationed at Fort Bonifacio, Makati,
Metro Manila, were walking along Quirino Avenue, Parañaque, Metro Manila. They had
just come from Camp Claudio where they attended a birthday party. While walking
along Quirino Avenue, they noticed two persons trailing them closely, about ten meters
away. They crossed the street ostensibly to avoid the two men following them.
One of them, Wilfredo del Rosario rushed to Nelson Sinoy and kicked the latter.
Armando Camat followed del Rosario and pulled out a knife and stabbed Nelson Sinoy.
Gonzalo Penalver kicked Camat who in turn stabbed the former, hitting him at the right
rib. Wilfredo del Rosario then grabbed the clutch bag from him.
Thereafter, Sinoy and Penalver ran away. With the aid of somebody who identified
himself as a policeman, they were brought to the San Juan de Dios Hospital. Sinoy died
there. Penalver was transferred to AFP Medical Center after his wounds were sutured
at San Juan de Dios Hospital.
Patrolman Odeo Cariño, to whom the case was assigned for investigation on
September 2, 1985, stated on the witness stand that appellant Camat orally admitted
to him his participation in the killing of the soldier during interrogation at the
police precinct. In addition, Camat also allegedly gave the names of Wilfredo del
Rosario and one Roland as his co-conspirators in the crime charged, and alluded
to appellant Del Rosario as the one who actually stabbed Sinoy. With this information,
Patrolman Cariño and another policeman traced the whereabouts of Del Rosario and,
when they found him, they invited him for questioning. In the police station, appellant
del Rosario allegedly confessed to Patrolman Cariño his involvement in the crime
and informed the latter that the electric tester could be recovered from his relatives.
Camat was pointed to by a vendor who allegedly saw what happened on the night of
Semptember 1, 1985. As fate would have it, Camat was arrested by Parañaque
policemen on October 11, 1985 for acts of lasciviousness, upon the complaint of his
sister-in-law. Since Camat fitted the description given earlier by the eyewitness to the
investigating policemen, Patrolman Cariño fetched the vendor to verify the identity of
Camat. At the police station, said witness recognized and identified Camat as the one
who killed Sinoy.
The Regional Trial Court rendered a decision of guilty.
Issue:
Whether or not the extrajudicial confessions made to Cariño by Camat and del Rosario
were admissible in evidence.
Held: NO
The Supreme Court held that both confessions were inadmissible as evidence as
these statements were made in the absence of counsel. The Court held in Morales,
Jr. vs. Enrile, et al. that “At the time a person is arrested, it shall be the duty of the
arresting officer to inform him of the reason for the arrest and he must be shown
the warrant of arrest, if any. He shall be informed of his constitutional rights to
remain silent and to counsel, and that any statement he might make could be
used against him. The person arrested shall have the right to communicate with
his lawyer, a relative, or anyone he chooses by the most expedient means — by
telephone if possible — or by letter or messenger. It shall be the duty of the
arresting officer to see to it that this is accomplished. No custodial investigation
shall be conducted unless it be in the presence of counsel engaged by the person
arrested, by any person on his behalf, or appointed by the court upon petition
either of the detainee himself or by anyone on his behalf. The right to counsel
may be waived but the waiver shall not be valid unless made with the assistance
of counsel. Any statement obtained in violation of the procedure herein laid
down, whether exculpatory or inculpatory, in whole or in part, shall be
inadmissible in evidence.”
In the present case, absent any showing that appellants were duly advised of the
mandatory guarantees under the Bill of Rights, their confessions made before
Patrolman Carino are inadmissible against them and cannot be used in support of
their conviction. Trial courts should further keep in mind that even if the confession of
the accused is gospel truth, if it was made without the assistance of counsel, it is
inadmissible in evidence regardless of the absence of coercion or even if it had
been voluntarily given.
As to the implication of Del Rosario in the extrajudicial confession of Camat, no reliance

can be placed on the imputation therein because it violates the rule on res inter alios
acta and does not fall under the exceptions thereto, especially since it was made after
the supposed homicidal conspiracy. An extrajudicial confession is binding only upon the
confessant and is not admissible against his co-accused. As against the latter, the
confession is hearsay.
However, the Supreme Court shared the opinion of the trial court that the prosecution,
despite presenting only a single witness, satisfactorily proved the guilt of the accused.
As such, the Court affirmed the decision of the lower court.

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CONFESSIONS

People v. Rodriguez, G.R. No. 112262, April 2, 1996-Panelo

The Regional Trial Court rendered a decision of guilty.

As to the implication of Del Rosario in the extrajudicial confession of Camat, no reliance

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