**Facts:**
On March 23, 2001, Rabel Campos was found dead with multiple stab wounds along the National Highway in Maputi, Naawan, Misamis Oriental. Teofilo Panangin was arrested on January 22, 2002, and during an NBI investigation on January 23, 2002, he executed a sworn statement implicating his former employer, Louel Uy, and described in detail the events leading to Rabel Campos’s murder.
Panangin stated that on March 22, 2001, Uy had solicited his assistance under threat, drew Rabel into a vehicle, and later ordered Panangin to stab her. Panangin complied under duress, after which Uy finished the act by repeatedly stabbing Rabel. Panangin’s sworn statement was made with the assistance of Atty. Celso Sarsaba of the Public Attorney’s Office.
The proceedings began with the local police recovering two pairs of sandals from the crime scene, which Panangin identified as his and the victim’s. Significantly, based on Panangin’s sworn statement, a murder charge was filed against both Panangin and Uy after a preliminary investigation. During this investigation, the judge found sufficient evidence suggesting both suspects shared a unified intent to kill Campos.
On April 5, 2002, an Information was filed against Uy and Panangin, charging them with murder. Both defendants pled not guilty. The prosecution presented several witnesses, including Atty. Sarsaba, NBI Agent Tamayo, and acquaintances of Uy and Campos who testified regarding the circumstances surrounding the crime.
Despite the prosecution providing 11 witnesses and physical evidence, including Panangin’s confession, Uy and Panangin filed separate demurrers to evidence, arguing that Panangin’s confession was involuntarily given and his rights under the Constitution were violated.
On April 7, 2003, the RTC granted the demurrers, citing insufficient evidence and ruling that Panangin’s confession was inadmissible since it resulted from an alleged illegal arrest. Despite acquitting the accused, the court held them jointly liable for P35,000 in burial expenses.
**Issues:**
1. Whether Panangin’s extra-judicial confession is admissible in evidence.
2. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
3. Whether the trial court committed grave abuse of discretion in granting the demurrer to evidence.
**Court’s Decision:**
1. **Admissibility of Panangin’s Confession:** The Supreme Court held that the trial court committed grave abuse of discretion by finding Panangin’s confession involuntary and inadmissible without sufficient basis. The trial court’s reliance on Panangin’s retraction (through an affidavit submitted months after the initial confession) without testimonial verification rendered its decision flawed. Panangin had competent legal assistance during the confession, who testified to the voluntary nature of the statement.
2. **Sufficiency of Evidence:** The Supreme Court determined the trial court prematurely dismissed the case without sufficiently considering all presented evidence, including Panangin’s confession and corroborative testimonies. The proper procedure would have been to let the defense present its case following the prosecution’s presentation, thus allowing a more comprehensive assessment.
3. **Grave Abuse of Discretion:** The Supreme Court found that not only did the trial court err in judgment, but it also acted with grave abuse of discretion. The trial court’s hasty acceptance of the demurrer deprived the prosecution of due process and violated the state’s right to present its case fully. The accused’s claims of duress and illegal arrest were not substantiated sufficiently to justify a dismissal.
**Doctrine:**
– A confession is presumed voluntary until proven otherwise, and an accused bears the burden of proving it was given involuntarily.
– Double jeopardy principles do not apply if a trial court grants a demurrer to evidence without due process considerations, thus failing to render a valid judgment.
– Grave abuse of discretion by a trial court can be ground to set aside a judgment of acquittal in a petition for certiorari.
**Class Notes:**
– **Elements of a Valid Confession:**
– Voluntariness – Accused must execute confession without coercion.
– Legal Assistance – Presence of a competent lawyer during the confession.
– Full Understanding – Accused should comprehend the rights and consequences.
– **Double Jeopardy:**
– Generally prohibits retrial after acquittal.
– Exception – No double jeopardy if acquittal by a court was rendered with grave abuse of discretion or violation of due process.
**Historical Background:**
This case reflects the Philippine legal system’s careful balancing of the preservation of constitutional rights against procedural integrity in criminal prosecutions. Highlighting critical aspects such as voluntariness in confessions, procedural due process for the prosecution, and limitations on the double jeopardy rule, the case underscores the complexities involved in administering justice. The case unfolded during a period of heightened awareness concerning human rights and due process within the Philippine judicial system.
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