**Facts:**
On 22 May 1987, Jaime “Jimmy” Agustin, along with Wilfredo “Sonny” Quiaño, Manuel “Jun” Abenoja, Jr., and Freddie “Boy” Cartel, were charged with murder, frustrated murder, and attempted murder for events occurring on 6 September 1986 in Baguio City. These events led to the death of Dr. Napoleon Bayquen and Anna Theresa Francisco, and the injuring of Anthony Bayquen, Dominic Bayquen, and Danny Ancheta. Quiaño, before arraignment, escaped custody. The cases against Agustin proceeded, and on 30 May 1990, he was acquitted in the frustrated and attempted murder cases but found guilty of two counts of murder, sentenced to reclusion perpetua due to treachery and aggravating circumstances. Agustin appealed, challenging the admissibility of his extrajudicial confession.
**Procedural Posture:**
The Supreme Court’s review was prompted by Agustin’s appeal, specifically questioning the admissibility of his extrajudicial confession based on the argument that it was obtained in violation of his constitutional rights.
**Issues:**
1. Whether the extrajudicial confession of Agustin was obtained in violation of his constitutional rights.
2. Whether the legal representation provided to Agustin during the custodial investigation was independent and competent.
3. The validity of Agustin’s arrest without a warrant and its impact on subsequent events, including the confession.
**Court’s Decision:**
The Supreme Court reversed the trial court’s decision, acquitting Agustin. The Court found that Agustin’s extrajudicial admission was inadmissible as evidence due to violation of his constitutional rights during the custodial investigation, specifically, his right to competent and independent legal counsel of his choice and the inappropriateness of his arrest. The Court extensively discussed the distinction between an extrajudicial confession and an extrajudicial admission, concluding what Agustin offered was the latter, which was inadmissible under the circumstances.
**Doctrine:**
– An extrajudicial confession obtained without the presence of counsel, or if the counsel provided is not independent and competent, is inadmissible as evidence.
– An individual’s right to counsel during a custodial investigation mandates not just any counsel, but competent and independent counsel preferably of their own choice.
– Any arrest made without a warrant must strictly comply with the conditions set forth under Section 5, Rule 113 of the Rules of Court. Absence thereof renders the arrest unlawful.
**Class Notes:**
– Distinction between extrajudicial confession and admission.
– Role and importance of competent and independent counsel during custodial interrogation.
– Conditions under which a warrantless arrest is considered lawful.
**Historical Background:**
This case underscores the critical importance of upholding constitutional rights during the legal processes, especially in matters involving custodial investigations and arrest procedures. It reflects the judiciary’s role in ensuring that these rights are not merely ceremonial but are effectively communicated, understood, and respected throughout legal proceedings.
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