People vs. Piedad-Case Digest
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Kuys XeeePeople vs. Piedad-Case Digest
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Kuys XeeePeople vs. Piedad, G.R. No.
131923, December 05, 2002
The right to counsel accrues only after an investigation ceases to be a general inquiry into an unsolved
crime and commences an interrogation aimed at a particular suspect who has been taken into custody
and to whom the police would then propound questions which tend to elicit incriminating statements.
The presence of counsel during such investigation is intended to prevent the slightest coercion as
would lead the accused to admit something false. What is thus sought to be avoided is the evil of
extorting from the very mouth of the person undergoing interrogation for the commission of an offense,
the very evidence with which to prosecute and thereafter convict him.
FACTS:
On April 10, 1996, Mateo Lactawan was assaulted by a group led by Niel Piedad, Lito
Garcia, and Richard Palma in Quezon City. Mateo was brought to the East Avenue
Medical Center where he later died because of the fatal injuries sustained.
Luz Lactawan, wife of Mateo, witnessed the assault and attempted to intervene, but
she too was apparently attacked and was injured. Police responded to a call from
East Avenue Medical Center and apprehended Lito, while Richard and Niel were
surrendered by their parents.
Witnesses, including Fidel Piquero, corroborated the events of the attack, indicating
the perpetrators and the actions taken.
All the accused pleaded not guilty, presenting a defense that contradicted the
witnesses’ statements. However, the trial court found Niel Piedad and Lito Garcia
guilty of murder, but Richard Palma was acquitted because of reasonable doubt.
Piedad and Garcia appealed the conviction. Accused-appellant Niel Piedad argues
that the way he was identified by prosecution witnesses was suggestive and fatally
flawed. Niel claims that he should have been put in a police lineup instead of being
shoveled into a "confrontation" with the alleged witnesses and immediately singled
out by the police as suspects. He further claims that he was denied his right of
counsel during the most crucial stage of the police investigation - that is, his
identification as one of the assailants by eyewitnesses.
ISSUE:
Whether or not the accused were deprived of their right to be represented by counsel during
the identification process.
RULING:
The Supreme Court held that the right to counsel accrues only after an investigation
ceases to be a general inquiry into an unsolved crime and commences an
interrogation aimed at a particular suspect who has been taken into custody and to
whom the police would then propound questions which tend to elicit incriminating
statements. The presence of counsel during such investigation is intended to prevent
the slightest coercion as would lead the accused to admit something false. What is
thus sought to be avoided is the evil of extorting from the very mouth of the person
undergoing interrogation for the commission of an offense, the very evidence with
which to prosecute and thereafter convict him.
The Court noted that in the case at bar, accused-appellants did not make any
extrajudicial confession or admission with regard to the crime charged. While Niel and
Lito may have been suspects, they were certainly not interrogated by the police
authorities, much less forced to confess to the crime imputed against them. Accused-
appellants were not under custodial investigation. In fact, Niel averred during cross-
examination that the police never allowed them to say anything at the police station
on the day they voluntarily presented themselves to the authorities.
The Court also found that Lito testified that he did not talk to any of the police officers
nor sign any written statement at the police station when he was invited. Moreover,
the rights accorded an accused under Section 12, Article III of the Constitution
applies only against testimonial compulsion and not when the body of the accused is
proposed to be examined, as was done in this case - presented to the witnesses to
be identified. Accused-appellants were not thus denied their right to counsel.
