**Facts:**
In Quezon City, on May 7, 1988, Dr. Demetrio Z. Madrid was robbed by a group while traveling in his Mercedes Benz. The robbers, armed and employing violence, stole various valuables totaling P363,600 and murdered Dr. Madrid’s driver, Lorenzo Bernales. Only Alejandro Lucero and two others, Bienvenido and Balbino Echavez, were apprehended; the rest remained at large. Lucero was interrogated without an effective legal counsel and produced an extrajudicial confession, which was later contested. During the trial, inconsistencies arose regarding the eyewitness’s (Dr. Madrid) identification of Lucero and the events surrounding Lucero’s confession. Despite this, the trial court convicted Lucero based on his contested confession and Madrid’s testimony, resulting in a sentence of reclusion perpetua and payment of damages. Lucero appealed the decision, questioning the weight given to the prosecution’s evidence, the proof of conspiracy, the validity of his confession, the reliability of his identification by Madrid, and the trial court’s reliance on the weakness of his alibi.
**Issues:**
1. Whether Lucero was given effective assistance of counsel during custodial investigation.
2. The validity of Lucero’s extrajudicial confession.
3. The credibility of witness identification that led to Lucero’s conviction.
4. Whether the prosecution satisfied their burden of proving Lucero’s guilt beyond a reasonable doubt.
**Court’s Decision:**
The Supreme Court reversed the trial court’s decision, acquitting Lucero. The Court found that Lucero was not provided effective counsel during his custodial investigation, violating his constitutional rights. The Court emphasized the necessity of vigorous defense during custodial interrogations and found Atty. Peralta’s representation inadequate, particularly as Lucero was left unattended during critical parts of the interrogation. Furthermore, the Court doubted the reliability of Dr. Madrid’s identification of Lucero, given the inconsistency and hesitation. These factors, combined with the inadmissibility of the extrajudicial confession, led to Lucero’s acquittal.
**Doctrine:**
This case underscores the inviolable right to counsel during custodial investigation, as mandated by the 1987 Philippine Constitution. It establishes the expectation of “effective and vigilant counsel,” especially during critical moments of interrogation, not merely a perfunctory or ceremonial presence of any lawyer.
**Class Notes:**
1. **Right to Effective Counsel:** During custodial investigations, the accused must not only be apprised of their right to remain silent and to an attorney but must also be provided with an effective and vigilant counsel actively involved in protecting their rights.
2. **Credibility of Witness Identification:** Courts must critically evaluate the process and circumstances surrounding eyewitness identification, recognizing factors such as the number of line-ups and environmental conditions during the crime that may influence reliability.
3. **Voluntariness of Confessions:** A confession made during custodial investigation without effective counsel or under duress is inadmissible as evidence.
4. **Burden of Proof:** The prosecution must prove guilt beyond a reasonable doubt, relying on solid evidence rather than the weaknesses of the defense’s arguments.
**Historical Background:**
This ruling is situated within a broader context of the Philippine legal system’s evolving approach to rights during custodial investigation post-Martial Law era. It demonstrates the commitment to upholding constitutional rights against coercion and ensuring justice is administered fairly, emphasizing the judiciary’s role in protecting individuals from miscarriages of justice irrespective of the crime’s gravity.
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