The Supreme Court held that the extrajudicial confession of a minor, obtained without proper regard for their rights and without considering the privileged mitigating circumstance of minority, cannot be the sole basis for a conviction carrying the death penalty. The Court emphasized the importance of ensuring that minors understand their rights and the consequences of their actions, particularly when facing serious criminal charges. This ruling underscores the judiciary’s commitment to protecting vulnerable individuals within the justice system.

Romeo’s Confession: Justice, Age, and the Weight of Admission

In the case of People v. Romeo Ugiaban Lumandong, the accused-appellant, Romeo Lumandong, was charged with the murder of eight-year-old Analou Eduave. The trial court convicted Lumandong based primarily on his extrajudicial confession, sentencing him to death. However, the Supreme Court, upon automatic review, reassessed the circumstances surrounding the confession, particularly noting Lumandong’s age at the time of the crime and the procedural safeguards required during custodial investigations.

The prosecution’s case heavily relied on Lumandong’s alleged confession to Barangay Captain Ruben Obsioma and a subsequent written statement taken with the assistance of counsel. Lumandong, however, claimed that he was coerced into confessing due to maltreatment by barangay officials and fear of the police. He also argued that his minority status was not properly considered during the trial. The key legal issue revolved around the admissibility of Lumandong’s confession and the appropriate penalty given his age.

The Supreme Court carefully examined the circumstances surrounding Lumandong’s confession, guided by the four fundamental requirements for its admissibility. These requirements are: (1) the confession must be voluntary; (2) it must be made with competent and independent counsel; (3) it must be express; and (4) it must be in writing. The Court scrutinized whether Lumandong’s confession met these stringent standards, especially given his claims of coercion and his status as a minor.

The Court found that while there was no concrete evidence of maltreatment during the custodial investigation, the trial court erred in not considering Lumandong’s minority at the time of the crime. The Court emphasized the doctrinal principle that a claim of minority must be upheld unless disproved by the prosecution, citing People vs. Villagracia:

“Consequently, the trial court erred when it failed to consider that appellant was a minor at the time of the commission of the crime. Minority being a privileged mitigating circumstance under Article 13(2) of the Revised Penal Code, as amended, appellant Lumandong should have automatically been spared the supreme penalty of death.”

Article 13(2) of the Revised Penal Code provides for minority as a privileged mitigating circumstance. This means that if the offender is a minor at the time of the commission of the offense, the penalty imposed should be reduced. Additionally, Article 68(1) provides that when the offender is over fifteen and under eighteen years of age, the penalty shall be lowered by one or two degrees. The convergence of these provisions is crucial in evaluating the culpability and corresponding penalty for juvenile offenders.

In considering the voluntariness of Lumandong’s confession, the Court acknowledged his claim of duress but found insufficient evidence to support it. The testimony of Homer Paduga, who accompanied Lumandong to the barangay captain’s house, contradicted Lumandong’s allegations of maltreatment. Moreover, the Court noted that Lumandong did not raise any complaints about coercion to the police, his counsel, or the administering officer, Atty. Casino. The Court stated:

“The failure of the appellant to present evidence of compulsion or duress or violence on his person and to complain to the officers who administered the oath are clear indications of the voluntariness of his confession.”

The presence of Atty. Emelgar Paasa from the Public Attorney’s Office (PAO) was also a significant factor in assessing the validity of the confession. The Court recognized that the assistance of an independent counsel ensures that the accused’s rights are protected and that any confession is obtained without force, threat, or intimidation. However, the primary concern remained Lumandong’s age and its implications under the law.

While the Court affirmed the presence of treachery and the aggravating circumstance of uninhabited place, it ultimately ruled that Lumandong’s minority entitled him to a reduced penalty. Treachery, which qualifies the killing as murder, was established due to the victim’s age. The Court agreed that the appellant deliberately took his victim to an isolated place, facilitating the commission of the crime.

Given Lumandong’s age of fourteen years, eight months, and fifteen days at the time of the offense, the Court applied Article 13(2) in relation to Article 68(1) of the Revised Penal Code. These provisions mandated a reduction of at least two degrees from the prescribed penalty for murder. With one aggravating circumstance present, the imposable penalty was reduced to prision mayor in its maximum period. Applying the Indeterminate Sentence Law, the Court imposed an indeterminate penalty of six years of prision correccional, as minimum, to ten years and one day of prision mayor, as maximum.

FAQs

What was the key issue in this case?	The key issue was whether the extrajudicial confession of a minor, obtained without proper consideration of his rights and age, could be the sole basis for a conviction carrying the death penalty. The Court scrutinized the confession’s admissibility and the proper penalty given the accused’s minority.
What is the privileged mitigating circumstance of minority?	Under Article 13(2) of the Revised Penal Code, being a minor at the time of committing a crime is a privileged mitigating circumstance. This generally results in a reduced penalty, recognizing the diminished capacity and understanding of young offenders.
What are the requirements for an admissible extrajudicial confession?	For an extrajudicial confession to be admissible, it must be voluntary, made with the assistance of competent and independent counsel, express, and in writing. These requirements ensure that the confession is obtained fairly and that the accused’s rights are protected.
How did the Court address the claim of coercion in this case?	The Court acknowledged the accused’s claim of coercion but found insufficient evidence to support it. The testimony of a witness contradicted the accused’s allegations, and the accused did not raise any complaints about coercion to the police, his counsel, or the administering officer.
What is the Indeterminate Sentence Law?	The Indeterminate Sentence Law allows the court to impose a minimum and maximum term of imprisonment, rather than a fixed sentence. This law aims to individualize punishment and provide opportunities for rehabilitation.
What was the final ruling in this case?	The Supreme Court affirmed the conviction for murder but modified the penalty. Given the accused’s minority, the death sentence was reduced to an indeterminate penalty of six years of prision correccional, as minimum, to ten years and one day of prision mayor, as maximum.
What is the significance of having counsel during custodial investigation?	Having competent and independent counsel during custodial investigation is crucial to protect the accused’s constitutional rights, particularly the right to remain silent and the right against self-incrimination. Counsel ensures that the accused understands these rights and that any statements made are voluntary and informed.
How did treachery affect the outcome of the case?	The presence of treachery qualified the killing as murder, which carries a higher penalty than homicide. Treachery exists when the offender employs means, methods, or forms in the execution of the crime that tend directly and specially to ensure its execution, without risk to himself arising from the defense which the offended party might make.

This case serves as a critical reminder of the judiciary’s role in safeguarding the rights of vulnerable individuals, especially minors, within the criminal justice system. The decision underscores the importance of adhering to stringent procedural safeguards during custodial investigations and considering privileged mitigating circumstances like minority when determining the appropriate penalty.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: THE PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ROMEO UGIABAN LUMANDONG, ACCUSED-APPELLANT., G.R No. 132745, March 09, 2000