People vs. Lugod [GR 136253, 21 February 2001]
case of rape with homicide homicide was fied a!ai"st the accused, accused, #eme"te #eme"te $oh" %u!od, for Facts: A case ae!edy rapi"! the ei!ht&year od !ir 'ictim, (airube $) Ramos a"d dumpi"! her dead body i" the !rassy coco"ut pa"tatio" area) *" +eptember 15, 1- at arou"d -.00 p)m), /ee" Ramos, the 'ictims mother, was aseep i" her house to!ether with her husba"d a"d their chidre", (imrod, (eres a"d (airube) At arou"d 12.30 a)m), they "oticed that (airube was !o"e) he bacdoor of their house was eft ope" where a pair of sippers that did "ot beo"! to the famiy was fou"d) " the mor"i"!, the poice be!a" their search for (airube wherei" a pa"ty beo"!i"! to the 'ictim was fou"d, as we as a bac coared shirt beo"!i"! to the accused, %u!od) 4it"esses testified that both sippers a"d the shirt were wor" by %u!od) %u!od was the" brou!ht to the poice statio" where he was temporariy i"carcerated) Athou!h he admitted to +*2 Gaardo that he raped a"d ied (airube, %u!ud refused to mae a stateme"t re!ardi"! the same) *" +eptember 1, 1-, the ice&7ayor 'isited the accused i" his ce) " the course of his co"'ersatio" with %u!od, %u!od ae!edy co"fessed to the commissio" of the offe"se) %u!od %u!od was char!ed char!ed for rape with with homici homicide) de) After After tria, tria, %u!od was fou"d !uity !uity a"d was se"te"ced to death) /e"ce, the automatic re'iew) Issue: 4hether or "ot %u!ods ae!ed co"fessio" ca" be used a!ai"st him8
arrest, records re'ea re'ea that accused&appe accused&appea"t a"t was "ot i"formed i"formed of his Held: At the time of his arrest, co"stitutio"a ri!hts to remai" sie"t a"d his ri!hts to cou"se) here is aso "o e'ide"ce to i"dicate that he i"te"ded to wai'e these ri!hts) #o"se9ue"ty, the accused&appea"ts act of co"fessi"! to +*2 Gaardo that he raped a"d ied (airube without the assista"ce of cou"se ca""ot be used a!ai"st him for ha'i"! tra"s!ressed accused&appea"ts ri!hts u"der the :i of Ri!hts) his is a basic te"et of our #o"stitutio" which ca""ot be disre!arded or i!"ored "o matter how bruta the crime committed may be) ;'e" if we were to assume that accused&appea"t was "ot yet u"der i"terro!atio" a"d thus, "ot e"tited to his co"stitutio"a ri!hts at the time he was brou!ht to the poice statio", the acts of accused&appea"t subse9ue"t to his apprehe"sio" ca""ot be characteri
