PEOPLE vs.

COMPIL

Facts:
Respondent was convicted of Robbery w/ Homicide after he,
together w/ his co-accused, robbed MJ Furnitures in Sta. Cruz,
Manila and leaving Manuel Jay killed as a consequence of the
robbery. Several days after the incident, respondent was caught in
Quezon Province by the police authorities. He was found lying on the
couch & was immediately frisked & placed under arrest. Accdg, to
Jenelyn, the wife of the deceased Manuel Jay, respondent turned
pale & became speechless & was trembling. However, after gaining
composure & upon being interrogated, he readily admitted his guilt.
He was then brought to the Tayabas Police Station where he was
further investigated. On their way back to Manila, he was again
interrogated until he confessed his involvement in the crime. The
day after his arrest, respondent, after conferring w/ CLAO lawyer
Claroz & in the presence of his sister Letecia, executed a sworn
statement admitting his participation as a lookout in the crime.

Issue: W/N there was violation of his Miranda Rights which will
render his extrajudicial confession inadmissible?

Held: YES!
It is evident that the respondent was immediately subjected to an
interrogation upon his arrest in Quezon Province. And the same goes
upon his transfer from Tayabas to Manila Police Station. The
arresting officers already elicited incriminating questions & he
confessed to the commission of the crime & admitted his
participation. All these, he was not assisted by counsel. The belated
arrival of the CLOA Lawyer the following day will not cure the
defect even if the actual signing of the uncounseled confession was
made in the presence of the counsel. The operative act is that when
the police investigation is no longer asking a general inquiry into an
unsolved crime but has began to focus on a particular suspect who
has been taken into custody by the police to carry out a process of
interrogation that lends itself to eliciting incriminating statements,
& not the signing of the extrajudicial confession. But the court still
finds other sufficient factual circumstances to prove his guilt beyond
reasonable doubt.