**People of the Philippines v. Nerio Suela y Hembra, Edgar Suela y Hembra, and Edgardo Batocan**
### Facts:
Three individuals, Nerio Suela y Hembra, Edgar Suela y Hembra, and Edgardo Batocan, were convicted by the Regional Trial Court of Quezon City for robbery with homicide and simple robbery. This case reached the Supreme Court for automatic review, bringing into question the proper legal procedures during custodial investigation, including the right to competent and independent counsel, and the retroactivity of procedural laws favorable to the accused.
The allegations originated from a robbery on July 26, 1995, at the residence of Director Nilo Rosas and the killing of Geronimo Gabilo. The prosecution’s narrative hinged on the events from the night of the crime to the subsequent identification and arrest of the appellants, bringing to light confessions, recoveries of stolen property, and identification by witnesses. The appellants were arraigned, pleaded not guilty, and went through a trial where a conviction was decided by the lower court.
### Issues:
1. Admissibility of the extrajudicial confessions of the appellants.
2. Admissibility of the wristwatch and the letter as evidence.
3. Conviction of the appellants for robbery with homicide.
4. Guilt of Edgar Suela for the charge of simple robbery.
### Court’s Decision:
The Supreme Court partly granted the appeal, modifying the decision from the death penalty to reclusion perpetua due to the inadmissibility of the extrajudicial confessions and lack of proper allegation of aggravating circumstances in the information. The court ruled the letter of Nerio Suela to be admissible, based on its voluntary nature outside of custodial interrogation. Edgar Suela was acquitted of the charge of simple robbery due to lack of intimidation or force demonstrated. The decision to convict on the grounds of robbery with homicide was upheld, based on evidence excluding the extrajudicial confessions and the wristwatch.
### Doctrine:
– The right to competent and independent counsel during custodial investigation is imperative, and any confession obtained in violation of this right is inadmissible.
– Procedural laws favorable to the accused are to be given retroactive effect.
– Aggravating circumstances must be explicitly alleged in the information to be appreciated in increasing penalty.
### Class Notes:
– **Extrajudicial Confessions**: Admissible only if the accused was informed of their rights and had competent and independent counsel.
– **Retroactivity of Procedural Laws**: Laws that benefit the accused apply retroactively.
– **Aggravating Circumstances**: Must be stated in the information to affect sentencing.
– **Evidence Admissibility**: The admissibility of evidence like letters and personal property hinges on the manner of acquisition and the context of its procurement.
### Historical Background:
This decision reiterates and applies existing jurisprudence regarding the rights of individuals under custodial investigation in the Philippines, reinforcing the necessity of safeguarding constitutional rights to ensure fair trial and due process.
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