Scribd
Upload
826 views2 pages

People Vs Dacanay

Antonio Dacanay was charged with parricide for stabbing his wife Norma to death. He claimed his extrajudicial confession to police was coerced. The RTC and CA found him guilty, relying on his confession. The Supreme Court upheld his conviction, finding that although he confessed in a detention cell, it was made to media not under custodial investigation. His constitutional rights were not violated as the confession was given to private individuals, not state agents. While best to inform detainees of consequences, the location alone did not render the confession inadmissible.

Uploaded by

jimmie alforque
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
826 views2 pages

People Vs Dacanay

Antonio Dacanay was charged with parricide for stabbing his wife Norma to death. He claimed his extrajudicial confession to police was coerced. The RTC and CA found him guilty, relying on his confession. The Supreme Court upheld his conviction, finding that although he confessed in a detention cell, it was made to media not under custodial investigation. His constitutional rights were not violated as the confession was given to private individuals, not state agents. While best to inform detainees of consequences, the location alone did not render the confession inadmissible.

Uploaded by

jimmie alforque
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
You are on page 1/ 2

PEOPLE OF THE PHILIPPINES v.

ANTONIO DACANAY y TUMALABCAB


G.R. No. 216064,NOV 7, 2016 , CAGUIOA, J.

FACTS:

An Information was filed with the RTC, accused-appellant Antonio T. Dacanay (Antonio)
was charged with the crime of Parricide under Article 246 of the Revised Penal Code
(RPC), as amended. That on or about October 06, 2007, in the City of Manila, Philippines,
the said accused, with intent to kill, did then and there willfully, unlawfully and
feloniously attack, assault and use personal violence upon the person of one NORMA
DACANAY y ERO, his wife, by then and there stabbing her body with an ice pick several
times, thereby inflicting upon her mortal stab wounds which were the direct and
immediate cause of her death thereafter. The RTC gave weight to the extrajudicial
confession of Antonio and found him guilty of the crime of Parricide. he CA affirmed the
RTC in to to and dismissed the appeal for lack of merit, on the ground that Antonio failed
toovercome the presumption of voluntariness attended by his extrajudicial confession.
In his defense, he averred that the twin defenses of alibi and denial, claiming coercion
and intimidation on the part of the police officers involved in the investigation of the
crime. In his Appeal, Antonio insists that his extrajudicial confession is inadmissible on
the ground that it was given under a "coercive physical or psychological atmosphere".
To support his claim, Antonio underscores the fact that he was inside a detention cell
with two(2) or three(3) other detainees when he allegedly confessed to the crime before
the media.

Issue:

Whether or not the extrajudicial admission is admissible in evidence

Held:

Yes. At the outset, we note that Antonio had already admitted in his Appellant's Brief
that he was not under custodial investigation at the time he gave his extrajudicial
confession. Although he was not under custodial investigation, note must be taken that
Antonio Dacanay was inside a detention cell with two (2) or three (3) other detainees
when he allegedly confessed before the media. Lastly, although confession before the
media does not form part of custodial investigation, Antonio Dacanay should have been
informed about the consequences of his when he decided to confess his alleged guilt.
Hence, Antonio's reliance on constitutional safeguards is misplaced as much as it is
unfounded. We need not belabor this point. We rule that appellant's verbal confessions
to the newsmen are not covered by Section 12 (1) and (3) of Article III of the
Constitution. The Bill of Rights does not concern itself with the relation between a
private individual and another individual. It governs the relationship between the
individual and the State. The prohibitions therein areprimarily addressed to the State
and its agents. They confirm that certain rights of the individual exist without need of
any governmental grant, rights that may not be taken away by government, rights that
government has the duty to protect. The fact that the extrajudicial confession was made
by Antonio while inside a detention cell does not by itself render such confession
inadmissible, contrary to what Antonio would like this Court to believe. In People v.
Domantay, where the accused was also interviewed while inside a jail cell, this Court
held that such circumstance alone does not taint the extrajudicial confession of the
accused, especially since the same was given freely and spontaneously.

You might also like

pFad - Phonifier reborn

Pfad - The Proxy pFad of © 2024 Garber Painting. All rights reserved.

Note: This service is not intended for secure transactions such as banking, social media, email, or purchasing. Use at your own risk. We assume no liability whatsoever for broken pages.


Alternative Proxies:

Alternative Proxy

pFad Proxy

pFad v3 Proxy

pFad v4 Proxy