FACTS:

The case involves accused-appellant Pablito Andan y Hernandez, also known as "Bobby," who was charged with the crime of rape with homicide. According to the information, Andan had carnal knowledge of the victim, AAA, against her will and without her consent. Andan also assaulted AAA with concrete hollow blocks, resulting in her death. The prosecution presented evidence that AAA was invited into Andan's house under false pretenses, then punched and raped. Andan left her unconscious in the house until dark, then transferred her body to a vacant lot, hitting her head with a piece of concrete block to ensure her death. AAA's body was discovered, and an autopsy determined the cause of death as the injuries inflicted by Andan. Evidence such as bloodstains, the victim's clothes, and a broken piece of concrete block stained with blood was recovered from Andan's house, as well as statements made by Andan admitting his involvement and implicating his neighbors.

The appellant, Pablito Andan (alias "Bobby"), was accused of committing the crime of rape with homicide against AAA. He was convicted and sentenced to death based on the testimonies of witnesses and evidence, including photographs and video footages of his confessions during custodial investigation. Appellant claims that his constitutional rights were violated as he was not assisted by counsel during the investigation. He also argues that the prosecution failed to prove his guilt beyond reasonable doubt. The case is now on automatic review before the Supreme Court.

The case revolves around the admissibility of the confession and evidence obtained from the accused, Pablito Andan. Andan was not informed of his constitutional rights during custodial investigation, yet he confessed to the police when questioned. The police also recovered bags from Andan's house based on information given by him, later identified as belonging to the victim. Andan confessed to the mayor that he committed the crime, begging for forgiveness. The defense argues that the confession and evidence obtained without the assistance of counsel should be considered inadmissible.

ISSUES:

1. Whether appellant's confession to the police is admissible in evidence due to the failure to inform him of his constitutional rights during investigation.

2. Whether the bags recovered from appellant's house are admissible as evidence.

3. Whether appellant's confession to the mayor is admissible as evidence.

4. Whether the admission of the accused was voluntary or obtained through threat, intimidation, or violence.

5. Whether the presence of the accused's uncle and other individuals during the interview affected the voluntariness of the admission.

6. Whether the accused was informed of the consequences of his admission.

7. Whether appellant's confessions to the news reporters are covered by the constitutional prohibition against self-incrimination.

8. Whether the medical evidence is sufficient to establish the commission of rape.

9. Whether the lacerations found in the victim's vagina could have been inflicted while she was alive.

10. Whether the absence of spermatozoa in the vagina and the lack of complete penetration or rupture of the hymen negate the commission of rape.

RULING:

1. Appellant's confession to the police is inadmissible as evidence since he was not informed of his constitutional rights during investigation.

2. The bags recovered from appellant's house are also inadmissible as evidence since they were the fruits of appellant's uncounselled confession to the police.

3. Appellant's confession to the mayor is admissible as evidence since it was not made in response to interrogation by the mayor and was given voluntarily and spontaneously in a private meeting.

4. The trial court held that the admission of the accused was voluntarily made. It ruled that there was no force or intimidation used during the interview, and that the accused admitted to the crime freely. The presence of the accused's uncle and other individuals did not affect the voluntariness of the admission. The court also found that the accused was informed of the consequences of his admission.

5. The court ruled that appellant's confessions to the news reporters are not covered by the constitutional prohibition against self-incrimination. The Bill of Rights does not concern itself with the relation between private individuals. It governs the relationship between the individual and the State. The prohibition against self-incrimination is primarily addressed to the State and its agents. The confessions were given freely and voluntarily, witnessed by the appellant's family, and were not obtained under any coercive atmosphere.

6. The court held that the medical evidence is sufficient to establish the commission of rape. The first autopsy conducted did not find spermatozoa and recent physical injuries in the hymen. However, a second autopsy revealed fresh lacerations in the hymen with clotted blood. The medico-legal officer testified that the lacerations may have been caused by an object forcibly inserted into the vagina, indicating the possibility of penetration.

7. The lacerations found in the victim's vagina were determined to have been inflicted while she was alive. The presence of clotted blood at the edges of the lacerated wounds supports this finding.

8. The absence of spermatozoa in the vagina and the lack of complete penetration or rupture of the hymen do not negate the commission of rape. What is essential is the penetration of the female organ, no matter how slight. In this case, the lacerations found in the victim's vagina serve as proof of penetration.

PRINCIPLES:

• Confessions made without the accused being informed of their constitutional rights during investigation are inadmissible as evidence.

• Evidence obtained as a result of uncounselled confessions is also inadmissible.

• The constitutional procedures on custodial investigation do not apply to voluntary and spontaneous statements made to law enforcement officers.

• Spontaneously made statements to news reporters in interviews are deemed voluntary and admissible as evidence.

• Admission of guilt can be considered voluntary if it is freely given without any form of coercion or intimidation.

• The presence of other individuals during the interview does not necessarily affect the voluntariness of the admission.

• It is important to inform the accused of the consequences of their admission to ensure that they fully understand the implications of their admission.

• The Bill of Rights primarily governs the relationship between the individual and the State. It lays down limitations to protect the individual against aggression and unwarranted interference by any department of government and its agencies.

• Constitutional prohibition against self-incrimination is addressed to the State and its agents. It does not cover the relationship between private individuals.

• Medical evidence is considered sufficient to establish the commission of rape when it shows fresh lacerations in the hymen, indicating the possibility of penetration.

• The absence of spermatozoa in the vagina and the lack of complete penetration or rupture of the hymen do not negate the commission of rape. (Note: Principle derived from previous rulings.)

• The presence of lacerations in the victim's vagina is evidence of penetration and supports the finding of rape.