**People of the Philippines vs. Ramon Bolanos**
### Facts:
The case began with a murder charge against Ramon Bolanos under Criminal Case No. 1831-M-90, following the death of Oscar Pagdalian. The prosecution built its case on the testimonies of Patrolmen Marcelo J. Fidelino and Francisco Dayao, along with Calixto Guinsaya and Dr. Benito Caballero. According to testimony, after a drinking spree, Patrolmen found Pagdalian dead with multiple stab wounds. They arrested Bolanos who allegedly confessed to the killing “because [Pagdalian] was abusive” while en route to the police station without a lawyer present. The Regional Trial Court of Malolos, Bulacan, Branch 14, convicted Bolanos, invoking his un-counseled confession. Bolanos appealed, challenging the admissibility of his confession, which led to a review by the Philippine Supreme Court.
### Issues:
1. Whether the constitutional rights of the accused-appellant were violated with the admission of his extra-judicial confession obtained without the presence of counsel.
2. Whether the conviction of the accused-appellant for murder was supported by evidence beyond a reasonable doubt, specifically in light of the alleged violation of his constitutional rights.
### Court’s Decision:
The Supreme Court reversed the Regional Trial Court’s decision, focusing on the violation of Bolanos’s constitutional rights during custodial investigation. It pointed out that the confession, made without counsel, violated Article III, Section 12 of the 1987 Constitution, which guarantees the right to counsel during interrogation. Since the confession was admitted in evidence against Bolanos and was a crucial factor in his conviction, and with no other evidence proving his guilt beyond reasonable doubt, the Court acquitted Bolanos.
### Doctrine:
This case reiterated the doctrine that any admission or confession obtained in violation of an accused’s right under custodial investigation is inadmissible in evidence against them. The Supreme Court emphasized the constitutional protections afforded to individuals under investigation, specifically the right to counsel, and how an infringement upon this right renders any confession obtained therein inadmissible in court.
### Class Notes:
– **Key Elements:**
– Right to Counsel: The case underscores the constitutional right of a person under investigation for the commission of an offense to have competent and independent counsel, preferably of their own choice.
– Admissibility of Confessions: A confession obtained without compliance with constitutional safeguards (Article III, Section 12 of the 1987 Constitution) is inadmissible as evidence.
– **Relevant Statutory Provisions:**
– 1987 Philippine Constitution, Article III, Section 12: Outlines the rights of individuals under investigation, including the rights to remain silent, have counsel, and the inadmissibility of evidence obtained in violation of these rights.
– **Application:** In criminal proceedings, if an accused’s confession is a key piece of evidence for conviction, it must be established that this confession was made with a full understanding of and compliance with the accused’s constitutional rights, particularly the right to legal counsel.
### Historical Background:
This case represents the judiciary’s guardianship of constitutional rights, reflecting broader post-Martial Law reforms in the Philippines aimed at strengthening civil liberties and protections against state abuse. It highlights the importance of procedural due process and the judiciary’s role in ensuring that the legal process respects constitutional rights, which were intensely scrutinized due to past abuses during Martial Law in the Philippines.
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