Case Digest - focusing on Admissibility of DNA evidence in the Supreme Court of the Philippines.Full description
People vs AmaguinFull description
John Dy vs PeopleFull description
People v Acierto case digestFull description
PEOPLE V. BRAVO
FACTS:
The decomposing body of nine year old girl Juania Anolin !Len"len# $as found in a %acan lo "" na&ed' shirless and s&ir pulled up' her pany su(ed in her mouh. )er body $as found abou *++ meers from her house. The scalp on he lef side of her head $as deached e,posing a fracure on he lef emporal lobe of her s&ull. Vaginal e,aminaion sho$e sho$ed d fresh fresh lacer lacerai aion on easil easily y accep acceps s $o -nger -ngers. s. The cause cause of deah deah $as cerebr cerebral al hemorrhage. An nformaion for rape $ih homicide $as -led agains herein accused"appellan. accused"appellan. )e $as arraigned and pleaded no guily. E%elyn E%elyn'' an eigh eigh year year old second second grader grader and neighb neighbor or and and cousin cousin of he %ici %icim m esi-ed ha she $as $ih he deceased he nigh before she disappeared. n cour' E%elyn posii%ely ideni-ed ideni-ed he appellan as he person las seen $ih Len"len before she $as found dead. dead. The o$ner o$ner of he house house $here $here Len"l Len"len en and E%elyn E%elyn $ach $ached ed ele%i ele%isio sion' n' /rac /racia ia 0onahan' corroboraed E%elyn1s esimony. The 2hief of he nelligence 3ecion of he 3aniago Police 4eparmen' Ale,ander Ale,ander 0ico' esi-ed in cour ha a he police saion he appellan admied he $as $ih he girl and and he carr carrie ied d her her on his his shou should lder er bu bu he $as so drun drun& & ha ha nigh nigh ha ha he does does no no remember $ha he did o her. On cross"e,aminaion 0ico admied ha he did no inform he appellan of his consiuional righs o remain silen' o counsel and of his righ agains self"incriminaion before he appellan made he said admission because according o 0ico he $as only informally informally iner%ie$i iner%ie$ing ng he accused accused $hen he made he admission admission and ha cusodial inerrogaion proper $as conduced by he assigned in%esigaor. HELD:
5e resol%e o ac6ui Benio Bra%o. 3ecion 78 of Aricle of he 79* 2onsiuion embo embodi dies es he he mand manda aor ory y pro proec eci ion on a(or a(orde ded d a pers person on unde underr in%e in%es sig iga aio ion n for for he he commission of a crime and he correlai%e correlai%e duy of he 3ae and is agencies o enforce such mandae. The manle of proecion under his consiuional pro%ision co%ers he period from he ime a person is a&en ino cusody for in%esigaion of his possible paricipaion in he commission of a crime or from he ime he is singled ou as a suspec in he commission of a crime alhough no ye in cusody. La$ enforcemen agencies are re6uired o e(eci%ely commun communica icae e he righ righs s of a person person under in%esig in%esiga aion ion and and o insur insure e ha ha i is fully fully undersood. Any informaion or admission gi%en by a person $hile in cusody $hich may appe appear ar har harmles mless s or inno innocu cuou ous s a he he ime ime $ih $ihou ou he he comp compe een en assi assis san ance ce of an independen counsel should be sruc& do$n as inadmissible. inadmissible. has been held' ho$e%er' ha an admission made o ne$s reporers or o a con-dan of he accused is no co%ered by he e,clusionary rule. The accused $as under arres arres for he rape and &illing of Juania Anolin and any saemen allegedly made by him peraining o his possible compliciy in he crime $ihou prior noi-caion of his consiuional righs is inadmissible in e%idence. The policeman1s apparen apparen aemp o circum%en circum%en he rule by insising ha he admission $as made during an ;informal al&; prior o cusodial in%esigaion proper is no enable. The appellan $as no in%ie in%ied d o he police police saio saion n as par par of a genera generall in6uir in6uiry y for any possib possible le lead lead o he perperaors perperaors of he crime under in%esigaion. in%esigaion.