PEOPLE v. RODOLFO DE LA CRUZ

FACTS:

The appellant, Rodolfo de la Cruz, was convicted for multiple murder in Criminal Cases Nos. 92-80829, 92-8030, and 92-8031 by the Regional Trial Court in Antipolo, Rizal. He appeals his conviction on the ground that he was not fully and appropriately informed of his constitutional rights during custodial investigation.

On June 23, 1992, the bodies of Teodorico M. Laroya Jr. and his children Karen Verona D. Laroya and John Lester D. Laroya were found in their residence in Cainta, Rizal. They had been stabbed multiple times, and each body had a knife still embedded in it. Karen Verona also showed signs of sexual assault.

Two neighbors, Harold Jim F. Balocating and Anita F. Pangan, testified that they discovered the bodies and that appellant, who was the brother-in-law of Teodorico Laroya Jr., had purchased candies from Pangan's store on the same day. Both Balocating and Pangan had previously given sworn statements after the incident, which were consistent with their testimonies in court.

On June 27, 1992, the police apprehended appellant at his brother's house. SPO1 Carlos R. Atanacio Jr., a member of the Cainta Police Station, interrogated appellant and claimed that appellant was informed of his rights, including the right to counsel, before he made a detailed extrajudicial confession.

Appellant, who had trouble expressing himself and had a speech impediment, denied Atanacio's version of events. He claimed that he was never assisted by any counsel and was instead tortured into signing the confession. Appellant admitted being at the victims' residence but denied killing them, stating that he left them alive and went to his brother's place.

Appellant argues that his rights were violated during custodial investigation, specifically that he was not fully informed of his rights and that his confession was obtained through coercion.

ISSUES:

  1. Whether the accused was fully and appropriately apprised of his constitutional rights before and during custodial investigation.

  2. Whether the extrajudicial confession obtained from the accused is admissible in evidence.

RULING:

  1. The accused has the right to be informed of his right to remain silent and to have independent counsel preferably of his own choice. The accused must be comprehensively and effectively informed of these rights in a language or dialect that he understands. A mere perfunctory reading of the rights would not suffice. In this case, the investigating officer failed to adequately inform the accused of his rights, thus rendering the confession valueless and inadmissible.

  2. The extrajudicial confession obtained from the accused is inadmissible in evidence since it was obtained in violation of the accused's right to be informed of his constitutional rights during custodial investigation.

PRINCIPLES:

  • Any person under investigation for the commission of an offense has the right to be informed of his right to remain silent and to have independent counsel preferably of his own choice. Failure to comply with these rights renders any confession or admission obtained inadmissible in evidence.

  • Custodial investigation begins when a person is taken into custody or otherwise deprived of his freedom of action in any significant manner, and the investigation ceases to be a general inquiry into an unsolved crime. The rights of the accused must be fully and comprehensively explained to him in a language or dialect that he understands.