G.R. Nos. 138934-35.
January 16, 2002 (Case Brief / Digest)
Title: People of the Philippines vs. Anthony Escordial
Facts:
1. Incident: On December 27, 1996, at around 8 PM in Bacolod City, Anthony Escordial was
accused of entering a boarding house where Michelle Darunday and two friends were
staying. Escordial allegedly robbed Darunday of P3,650.00 and raped her twice, once
vaginally and once anally, while threatening her with a knife.
2. Investigation and Arrest: The crime was immediately reported, but Escordial was only
arrested on January 3, 1997, without a warrant due to a tip from a café owner stating
Escordial fit the description given by the victims.
3. Court Proceedings: Following the arrest, Escordial was identified by the victims during
a show-up and later at a police line-up. He was charged with robbery with rape (Criminal
Case No. 97-18118). He pleaded not guilty at his arraignment on February 25, 1997.
4. Trial: The prosecution presented several witnesses, including the victims and the
arresting officer, while Escordial asserted an alibi claiming he was not in Bacolod during the
night of the crime. The defense argued that the police identification process was improperly
conducted and that the arrest was unlawful.
Issues:
1. Illegality of Arrest: Whether the arrest of Anthony Escordial, which was conducted
without a warrant, was legal and if it affected the admissibility of evidence obtained as a
result.
2. Violation of Constitutional Rights: Whether Escordial’s rights to remain silent and to
have counsel during custodial investigation were violated.
3. Credibility and Admissibility of Identification: Whether the in-court and out-of-court
identifications of Escordial by the victims were legally and credibly conducted, considering
the alleged suggestiveness of the identification procedures.
4. Proof Beyond Reasonable Doubt: Whether the evidence presented against Escordial
was sufficient to establish his guilt beyond a reasonable doubt.
Court’s Decision:
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G.R. Nos. 138934-35. January 16, 2002 (Case Brief / Digest)
1. Illegality of Arrest: The Supreme Court held that while the arrest without a warrant
was illegal, Escordial waived his right to challenge it by pleading not guilty and
participating in the trial without objection.
2. Constitutional Rights: The Court found that despite the violation of constitutional
rights during custodial investigation, no uncounseled admission or statement was used
against Escordial in the trial.
3. Identification: The Supreme Court ruled the identification during the show-up and
police line-up without the presence of counsel inadmissible. However, the failure of the
defense to immediately challenge this during trial led to waiver of this issue.
4. Credibility of Witnesses: The Court questioned the credibility of the witnesses’
testimonies and identifications due to inconsistencies and possible suggestiveness.
Especially, eyewitness identifications were found unreliable due to discrepancies between
their descriptions and Escordial’s actual appearance.
5. Acquittal: Given the questionable quality of the identification evidence and the lack of
proof beyond reasonable doubt, the Supreme Court acquitted Escordial of the charges.
Doctrine:
– Waiver of Rights Objection: Failure to contest illegal arrest before plea or trial
participation waives the objection.
– Identification Procedures: Uncounseled out-of-court identification during custodial
investigation is inadmissible; nonetheless, if not immediately objected to, it can be
considered waived.
Class Notes:
– Elements of Robbery with Rape: Intent to gain, violence or intimidation, and non-
consent in sexual violation.
– Warrantless Arrest Parameters: Article III, §2 of the Philippine Constitution; Rule 113
Sec. 5 outlines allowable conditions.
– Right to Counsel: Article III, §12 of the Constitution mandates that any accused has a
right to a counsel during custodial investigations.
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G.R. Nos. 138934-35. January 16, 2002 (Case Brief / Digest)
Historical Background:
This case illustrates critical aspects of criminal procedure in the Philippines, particularly
relating to warrantless arrests and the rights of the accused during custodial investigations.
It underscores the balance between effective law enforcement and the protection of
constitutional rights. The Court’s decision reflects a heightened scrutiny of procedural
adherence, particularly in serious criminal offenses with grave penalties like rape and
robbery.
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