Scribd Logo
Upload

Welcome to Scribd!

  • 131 views

    85 People v. Rodriguez

    Uploaded by

    Rostum Agapito
    1. Rodriguez and Artellero were convicted of murder for the killing of a bank security guard based on Rodriguez's confession and circumstantial evidence. 2. The Supreme Court found Rodriguez's confession to be constitutionally flawed and inadmissible. It also found the evidence against the two men to be "inextricably linked". 3. Since the appellate court acquitted co-defendant Artellero and this judgment was favorable and applicable to Rodriguez, the Court reversed their convictions and acquitted both men.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    85 People v. Rodriguez

    Uploaded by

    Rostum Agapito
    131 views1 page
    1. Rodriguez and Artellero were convicted of murder for the killing of a bank security guard based on Rodriguez's confession and circumstantial evidence. 2. The Supreme Court found Rodriguez's confession to be constitutionally flawed and inadmissible. It also found the evidence against the two men to be "inextricably linked". 3. Since the appellate court acquitted co-defendant Artellero and this judgment was favorable and applicable to Rodriguez, the Court reversed their convictions and acquitted both men.

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    1. Rodriguez and Artellero were convicted of murder for the killing of a bank security guard based on Rodriguez's confession and circumstantial evidence. 2. The Supreme Court found Rodriguez's confession to be constitutionally flawed and inadmissible. It also found the evidence against the two men to be "inextricably linked". 3. Since the appellate court acquitted co-defendant Artellero and this judgment was favorable and applicable to Rodriguez, the Court reversed their convictions and acquitted both men.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    131 views1 page

    85 People v. Rodriguez

    Uploaded by

    Rostum Agapito
    1. Rodriguez and Artellero were convicted of murder for the killing of a bank security guard based on Rodriguez's confession and circumstantial evidence. 2. The Supreme Court found Rodriguez's confession to be constitutionally flawed and inadmissible. It also found the evidence against the two men to be "inextricably linked". 3. Since the appellate court acquitted co-defendant Artellero and this judgment was favorable and applicable to Rodriguez, the Court reversed their convictions and acquitted both men.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    of 1

    [85] People v. Rodriguez (FRANCISCO) prison, unless held for another lawful cause.

    unless held for another lawful cause. The Director of Prisons is directed to inform this
    Oct 2, 2000 | Quisumbing, J. | Criminal Appeals Court of his compliance, within ten (10) days from receipt of this Decision. No costs.

    PETITIONER: People of the Philippines RATIO:


    RESPONDENTS: Wilfredo Rodriguez and Larry Artellero 1. An appeal in criminal proceeding throws the whole case open for review of all its aspects,
    including those not raised by the parties.
    DOCTRINE: The evidence against and the conviction of both accused are inextricably 2. Rodriguez withdrew his appeal for financial reasons. However, Sec. 11 (a) of Rule 122 of
    linked. Hence, Artellero’s acquittal, which is favorable and applicable to Rodriguez should the Rules of Court provides that an appeal taken by one or more of several accused shall
    benefit the latter. Sec. 11 of Rule 122 provides the effect of appeal by any of several not affect those who did not appeal, except if the judgment of the appellate court is
    accused: “An appeal taken by one or more of several accused shall not affect those who favorable and applicable to the latter.
    did not appeal, except insofar as the judgment of the appellate court is favorable and 3. Rodriguez’s confession is constitutionally flawed so it could not be used as evidence
    applicable to the latter”. against them at all. 4 fundamental requisites for the admissibility of a confession are:
    e. voluntary
    FACTS: f. made with the assistance of competent and independent counsel
    1. Artellero was employed as a cement mixer and helper of co-accused Rodriguez, a mason g. express
    in the construction of the upper floors of Far East Bank and Trust Company at Sta. Cruz, h. in writing
    Manila. A messenger discovered the lifeless body of Matias (bank security guard) inside 5. The second requisite is lacking. The accused were detained for 4 days, but the PAO lawyer
    the bank premises, tied with a nylon cord and 32 stab wounds. was called only on the 4th day when accused was about to put his confession in writing.
    2. In a follow-up investigation, the police went to the barracks of the constructions workers The moment that the 2 were arrested as suspects and brought to the police station, they
    and saw Rodriguez packing his personal belongings stating that he has nothing more to do were already under custodial investigation and should be accorded their rights under the
    there. They saw reddish stains on his shirt and on a pair of maong pants on the bed. Constitution (particularly the right to counsel).
    Rodriguez said he had a wound on his neck, but the police found none upon examination. - Records do not show that both were informed of their Miranda rights.
    3. They arrested the two. Rodriguez executed a sworn statement confessing that he and - They were not provided with competent and independent counsel during the custodial
    Artellero, along with Mendoza and two others killed Matias. Both were charged with investigation prior to the execution of the extrajudicial confession.
    robbery with homicide for the killing of Matias. 6. Admissions obtained during custodial investigation without the benefit of counsel,
    4. Witnesses were presented by the prosecution and one testified that the reddish stains on although later reduced into writing and signed in the presence of counsel are still flawed
    Rodriguez’s pants and shirt were positive for type O human blood, which was also the under the Constitution.
    blood type of Rodriguez. 7. The extrajudicial confession of Rodriguez is inadmissible and it was an error of the trial
    5. Witnesses for the defense testified that the bank policy prohibits guards from allowing court to use it in convicting the two.
    persons from entering the bank after office hours except for official visitors from higher - Rodriguez: relied on his confession (inadmissible)
    banks and both accused. - Artellero: relied on 2 pieces of circumstantial evidence which show conspiracy:
    6. Both admitted that they slept inside the building on the night before the incident but denied a. Extrajudicial confession of Rodriguez implicating him (inadmissible)
    killing Matias. Policemen allegedly mauled Rodriguez to confess and did not ask for the b. Maong pants allegedly belonging to him with type O blood stains (no probative
    statement of Artellero. The latter also denied owning the maong pants. value since his blood type and that of the victim were not taken for purposes of
    7. RTC: GUILTY of murder. Robbery with homicide was not the proper charge. Acquitted comparison
    from robbery due to insufficiency of evidence. 8. Assuming arguendo the extrajudicial confession was admissible, Rule 130 of ROC
    8. Both appealed, but Rodriguez withdrew his appeal for financial reasons. Artellero provides that such can only be admissible against the confessant. There must be
    contended that the trial court erred in: independent evidence aside from the same to prove conspiracy. In this case, no other
    a. giving credence to the extrajudicial confession of Rodriguez (implicating him as co- evidence was presented.
    conspirator) 9. The evidence against and the conviction of both accused are inextricably linked. Hence,
    b. finding the maong pants stained with blood type “O” belongs to him Artellero’s acquittal, which is favorable and applicable to Rodriguez, should benefit the
    c. admitting the fact that they worked and slept together for 6 months as part of latter.
    circumstantial evidence; and
    d. rendering a decision more serious than charged in the information.

    ISSUE: W/N the appeal taken by Artellero shall affect Rodriguez’s conviction despite the
    withdrawal of his appeal– YES

    WHEREFORE, the decision of the trial court convicting appellant LARRY ARTELLERO y
    RICO and co-accused WILFREDO RODRIGUEZ y CULO is hereby REVERSED. Appellant
    and Rodriguez are ACQUITTED of the crime of murder and ordered immediately released from

    You might also like