People of the Philippines, plaintiff-apellee, vs. Domingo R.

Muleta, accused-appellant
G.R No. 130189, June 25, 1999

FACTS:
Charito Delgado, 19 years old, went to Manila on April 15, 1993 to find work and she stayed in Tondo, Manila. When
she found a job, she decided to move to Valenzuela, Manila. On April 23, 1993, she picked up her remaining
baggage from Tondo. On April 30, 1993, her lifeless body was found raped with multiple stab wounds.
Based on NBI Investigation, Charito’s uncle, herein accused Domingo Muleta was picked up and “invited” for
investigation. During said investigation, Muleta, assisted by counsel, admitted having raped and killed Charito and he
signed an extrajudicial confession.
During trial, several circumstantial evidences including affidavits and testimonies against Muleta were presented.
Muleta withdrew his confession citing undue influence and duress in extracting said confession. He also raised alibi
as a defense, among others.
ISSUES:
1. Is the Extrajudicial Confession valid and admissible or is it in violation of the accused Constitutional rights,
hence not admissible?
2. Is there sufficient evidence to prove accused-appellant’s guilt beyond reasonable doubt and overturn his
right to presumption of innocence?
3. Is alibi a defense?
RATIONALE:
1. To be admissible, an extrajudicial confession must conform with Constitutional requirements and must
conform with the rights of the person under investigation, INCLUDING RIGHT TO BE INFORMED. Here,
there was no voluntariness or understanding on the part of the accused. The “invitation” by NBI was in
reality a custodial investigation where the accused was not assisted by counsel. The accused must have
been accorded the right to counsel from the time that he was brought to the NBI and not later. Accused was
not assisted by lawyer when he waived his right in his confession and it was not in a language the clearly
manifested his desire to do so. The lawyer made no effort to determine whether the accused was treated
well or if he understood his rights.
2. All the pieces of circumstantial evidence were controverted by the defense, and more importantly, were not
sufficiently established. The confession, being inadmissible, hence, all circumstantial evidence presented
acquire no significance.
3. Alibi is considered inherently weak because it can be either easily fabricated or difficult to disprove.
RULING:
Accused is ACQUITTED