Right of the Accused
The right of the accused is a fundamental principle enshrined in the 1987 Philippine Constitution. Article III, Section 14 specifically states: “No person shall be held to answer for a criminal offense without due process of law,” and further emphasizes that “In all criminal prosecutions, the accused shall be presumed innocent until the contrary is proved, and shall enjoy the right to be heard by himself and counsel.” These constitutional provisions ensure vital protections, including due process, the presumption of innocence, the right to counsel, and protection against self-incrimination.
The rights of the accused in the Constitution are intended to safeguard individuals from arbitrary and unjust treatment during criminal proceedings. The Supreme Court has consistently upheld these protections, reinforcing the importance of due process, the right to counsel, a speedy trial, the presumption of innocence, and the right against self-incrimination. In recent years, the Court has reaffirmed its commitment to these safeguards, underscoring their role in ensuring fairness and justice within the criminal justice system.
1. Right to Due Process
• People v. Sandiganbayan (G.R. No. 96037, January 16, 1991)
Factual Background: The case involved a public official charged with graft. The accused claimed that he was denied due process when the Sandiganbayan rendered judgment without considering his defenses adequately.
Ratio Decidendi: The Supreme Court ruled that due process means giving the accused a fair opportunity to be heard. In this case, the accused was given all the chances to present evidence, and the court determined that his rights were not violated. The judgment emphasized that due process is observed as long as the accused is given the opportunity to defend himself.
• Aguinaldo v. People (G.R. No. 227563, September 3, 2019)
Factual Background: Aguinaldo was convicted of illegal possession of drugs based on circumstantial evidence. He argued that the evidence against him was insufficient, and he was convicted despite the presumption of innocence.
Ratio Decidendi: The Supreme Court acquitted Aguinaldo, emphasizing that the right to due process is intertwined with the presumption of innocence. The Court found that the prosecution failed to prove guilt beyond a reasonable doubt, underscoring that any doubt should be resolved in favor of the accused.
2. Right to Counsel
• People v. Jalosjos (G.R. No. 132875, July 16, 2003)
Factual Background: Jalosjos, a former Congressman, was charged with statutory rape. He argued that during his interrogation, he was denied the assistance of counsel.
Ratio Decidendi: The Court held that the right to counsel is fundamental, especially during custodial investigations. Without the presence of counsel, any admission or confession obtained is inadmissible as evidence. In Jalosjos’ case, his right to counsel was violated, although this did not automatically lead to an acquittal since other evidence was considered sufficient for conviction.
• Valenzuela v. People (G.R. No. 222897, August 13, 2019)
Factual Background: Valenzuela was arrested for illegal possession of firearms, and during the investigation, he made self-incriminating statements without the presence of a lawyer.
Ratio Decidendi: The Supreme Court ruled that any confession made by an accused without the assistance of counsel is inadmissible in court, emphasizing the constitutional right against self-incrimination. The Court acquitted Valenzuela, stating that his confession was improperly obtained.
3. Right to a Speedy Trial
• Sison v. Gatchalian (G.R. No. 218929, March 8, 2016)
Factual Background: Sison was facing charges for over a decade due to multiple delays in court proceedings. He filed a motion to dismiss, arguing that his right to a speedy trial was violated.
Ratio Decidendi: The Supreme Court ruled in favor of Sison, dismissing the case due to the unreasonable delay. The Court emphasized that a speedy trial is a fundamental right, and unnecessary delays, especially if caused by the prosecution or the court, violate the accused’s rights.
• Dela Cruz v. People (G.R. No. 218038, February 4, 2020)
Factual Background: Dela Cruz was charged with estafa, and the case dragged on for years due to constant resetting of hearings. He argued that this violated his right to a speedy trial.
Ratio Decidendi: The Supreme Court ruled that delays in the justice system should not prejudice the accused. Since the prosecution failed to justify the delay, the Court dismissed the case, reaffirming the right to a speedy trial.
4. Presumption of Innocence
• Aguinaldo v. People (G.R. No. 227563, September 3, 2019)
Factual Background: Aguinaldo was convicted for drug-related charges based on weak circumstantial evidence. He claimed that his presumption of innocence was not properly upheld.
Ratio Decidendi: The Court held that the presumption of innocence is a fundamental right that can only be overturned by proof beyond a reasonable doubt. Since the evidence against Aguinaldo was insufficient, the Court overturned the conviction and acquitted him.
• People v. Garcia (G.R. No. 227398, August 7, 2019)
Factual Background: Garcia was convicted of theft based on witness testimonies, despite conflicting evidence. He appealed on the ground that the presumption of innocence was not respected.
Ratio Decidendi: The Court acquitted Garcia, emphasizing that the presumption of innocence cannot be overcome by mere suspicion or conjecture. The burden is on the prosecution to prove guilt beyond a reasonable doubt, and in this case, the evidence was insufficient to support a conviction.
5. Right Against Self-Incrimination
• Valenzuela v. People (G.R. No. 222897, August 13, 2019)
Factual Background: During his arrest for illegal possession of firearms, Valenzuela was coerced into confessing without being informed of his right to remain silent or to have counsel present.
Ratio Decidendi: The Supreme Court ruled that the right against self-incrimination protects individuals from being compelled to testify against themselves. Since Valenzuela was not informed of his rights, his confession was deemed inadmissible. The Court also reiterated that a violation of this right warrants the exclusion of any illegally obtained evidence.
• People v. Ligsay (G.R. No. 211016, July 26, 2017)
Factual Background: Ligsay was charged with murder. During interrogation, he admitted to the crime without the presence of a lawyer and claimed that his confession was coerced.
Ratio Decidendi: The Court ruled that any confession obtained without informing the accused of their right to counsel or without counsel present is inadmissible. The ruling reinforced the importance of the right against self-incrimination in protecting the accused from abusive practices.