Dramayo
FACTS: Dramayo and Ecubin accompanied the deceased to the chief of
police to be witnesses on a robbery which took place on the house of the
deceased but they were then included as prime suspects. To prevent the
deceased on testifying for the robbery case, Dramayo with Ecubin invited 5
of their friends to a drinking session where they brought up the plan of
killing the deceased. The killing took place where only Dramayo and Ecubin
actually contributed to the killing. However, all 7 of them were accused of
murder, but 2 were utilized as state witnesses, 3 were acquitted for lack of
proof beyond reasonable doubt, and only Dramayo and Ecubin were
convicted, though the offense was charged to have been committed with
conspiracy. It was the contention of the defense that since the crime
charged involves conspiracy and the other accused were acquitted beyond
reasonable doubt, Dramayo and Ecubin should also be acquitted for lack of
proof beyond reasonable doubt.
DOCTRINE: Even if the other defendants in a crime charged with
conspiracy were acquitted, if moral certainty arisen in some of them as to
their culpability, the PRESUMPTION OF INNOCENCE cannot come to their
rescue as it was sufficiently overcome by proof beyond reasonable doubt
establishing moral certainty that they are guilty of the offense charged.
People vs. Holgado
FACTS: Holgado, a private person, was accused of slight illegal detention
for detaining Artemia in a house for 8 hours. When he was presented to the
court for arraignment, the judge asked him Do you have an attorney or
are you going to plead guilty?. He answered I dont have an attorney and
Im going to plead guilty. Judgment was rendered convicting him of
Kidnapping and Serious illegal detention.
DOCTRINES:
The INFORMATION CHARGES an offense of slight illegal detention on its
caption and the allegations on the information were ambiguous. The
conviction must only be for the offense he has pleaded since no
evidence was presented to prove a higher offense.
be arrested, 2 were non employees while one was an employee of the post
office, Marcelo. NBI asked them to sign the envelops involved as a proof
that those were the envelops seized from them during the arrest. It was
the contention of the defense that the act of having them sign the
envelops without a counsel is against their RIGHT AGAINST SELFINCRIMINATION.
DOCTRINE: Since the signing of the envelops was done during a custodial
investigation without the presence of a counsel, the petitioners admission
that the letters they signed were those seized from them is inadmissible as
testimonial evidence. However, the envelops can stand on their own and
admissible as they were the ones seized from the accused as an incident of
a valid arrest, thus, the envelops themselves are admissible in court.
People vs. Matos-Viduya
FACTS: The wife was accused of parricide for killing his lawyer husband.
She initially denied the allegations by executing 2 affidavits, one stating
that it was a result of a robbery by their former employee and another
person, and the other affidavit executed to include their driver as the other
robber who actually killed her husband. The wife then executed an
extrajudicial confession without the presence of her own counsel as she
said that the presence of the fiscal in that room is enough Andyan
naman si fiscal kaya hindi ko na kailangan ng abogado.
DOCTRINE: The EXTRA-JUDICIAL CONFESSION has no probative value
although it was executed with the presence of the fiscal for the latters
duty is to prosecute crimes and cannot pretend to be a defense counsel
even only during a custodial investigation. A counsel required for the
accused is one who will effectively undertake his clients defense without
any intervening conflict of interest. Hence, the extrajudicial confession
cannot be taken as evidence to prove guilt beyond reasonable doubt.
Acquitted.
People vs. Declaro
FACTS: A charge of slight physical injury was filed against the accused as
a result of traffic accident. Another case was later filed for serious physical
injury. The first case was dismissed by Hon.Declaro granting the motion of
the counsel for the accused on ground of lack of interest on the part of the
prosecution. Due this, the second case was dismissed as well on the
ground of DOUBLE JEOPARDY.
DOCTRINE: Legal jeopardy attaches only:
1. Upon a valid complaint
2. Before a competent court
3. After arraignment
4. A valid plea having been entered
5. Defendant was acquitted or convicted, or case was dismissed or
terminated without express consent of the accused.
requirement for public trial is satisfied if the accused could have his
friends, relatives and counsel present at the trial. Hence, right to public
trial was not violated in this case. And even if to consider it in violation of
their right to public trial, as held in another case by the SC, if accused
offered no objection to it during trial, his right is deemed waived.
Villareal died pending his petition; hence, his liability was extinguished.
Dizon appealed invoking his right to DUE PROCESS for being wrongfully
declared to have waived his right to present evidence. The trial court
set 5 dates for him to present evidence but he was asked to present it
at an earlier date because one of the accused did not present evidence
and only adopted the evidences of the other accused. He was unable
to present his evidence on the earlier date, then court declared it as
his waiver to present evident.
Sol.Gen. appealed the conviction of the 4 accused for only slight
physical injury.
Sol.Gen. assailed the dismissal of the other 4 accused grounded on
their right to SPEEDY TRIAL.
DOCTRINES:
The court should have considered the excuse of Dizons counsel
justified since counsel for another accused had made a last-minute
adoption of testimonial evidence that accelerated the succeeding trial
dates, and Dizon was not really scheduled to testify on that day. The
trial court should have only considered it as a waiver to present
evidence on one day and allowed him to present it on the other set
dates. Stripping off all the pre-assigned trial dates constitutes a denial
of right to due process. Nevertheless, it wont vacate the finding of the
guilt of the accused when facts had been adequately represented and
no procedural unfairness or irregularity has prejudiced the accused or
the prosecution, hence, the guilty verdict may still be upheld since it is
supported by evidence beyond reasonable doubt.
The court, however, correctly dismissed the case of the 4 accused on
ground of speedy trial as their case has been dormant for a
considerable length of time. There had been no action on their case for
almost 7 years but the pleadings and one motion to set case for trial
which court did not act upon. This prolonged inactivity is precisely the
kind of delay that the constitution frowns upon. Though the delay of
the trial are justifiable, it is nonetheless clear that their right to speedy
trial has been violated in this case.