You are on page 1of 2

People vs.

Camat

FACTS:

Amboy Camat and Willie Del Rosario were accused of roberry with homicide on a certain Nelson Sinoy
and Gonzalo Penalver. Camat divested Penalver of a black leather clutch bag containing an electric tester
valued at P150 and stabbed the victim. Del Rosario on the other hand stabbed Sinoy which caused the
latters death, Penalver survived with serious injuries.

Both accused admitted to Pat. Odeo Carino their involvement in the crime upon invitation in the police
station.

At their arraignment, appellants pleaded not guilty to the crime charged. After due hearing, the lower
court rendered judgment 2 on June 19, 1987 finding both appellants guilty beyond reasonable doubt of
the crime of robbery with homicide and frustrated homicide. Appellants assigning in their brief a single
error submitting that the court gravely erred in finding them guilty beyond reasonable doubt of the crime
of robbery with homicide and frustrated homicide.

In support of their lone assignment of error, appellants insist that the trial court cannot rely on the
extrajudicial confession of appellant Camat as a basis for their conviction because such confession was
obtained during custodial investigation in violation of their constitutional rights.

ISSUE:

WON the trial court erred in relying on the extrajudicial confessions of the accused as basis for their
conviction because such confession was obtained in custodial investigation in violation of their
constitutional rights.

HELD:
Yes. Absent any showing that appellants were duly advised of the mandatory guarantees under the Bill of
rights, their confessions made before Pat. Carino are inadmissible against them, and cannot be used in
support of their conviction. However, SC still affirmed their guilt.

1. People vs. DiosdadoCamat, GR 188612, 30 July 2012 (Illegal possession-proof)

Facts: Between 3:00 oclock and 5:00 oclock in the afternoon, the victims (the hidalgos and others),
were in front of the yard Anastacio Hidalgo seated and talking to each other when gunfire coming from
the back of and directed at the group of Aurelio suddenly erupted. After shooting their victims, accused
and their companions left the place going westward. Aurelio recalled that prior to the shooting incident;
one of the accused hacked the house of Juanito Hidalgo, Aurelios brother, with a bolo, and had the
hacking incident blottered at the barangay. The trial court found Camat guilty of two counts of the crime
of Murder with the Use of Unlicensed Firearm and four counts of Attempted Murder. On the other
hand, the trial court found Dulay guilty of two counts of Murder with the Use of Unlicensed Firearm and
one count of Frustrated Murder.

Issue: Whether the use of unlicensed firearm was not duly proven by the prosecution?
Ruling: Yes. The Court found that the use of unlicensed firearm was not duly proven by the prosecution.
The evidence indicates that none of the firearms used in the massacre were ever recovered and
presented in the trial court. Nevertheless, there is jurisprudence which states that the existence of the
firearm can be established by testimony, even without the presentation of the firearm. The testimony
of the prosecution witnesses had established that appellant Camat used a long firearm of unknown
make and caliber to shoot his victims but that would still be insufficient to attribute to his felonious act
the qualifying circumstance of use of unlicensed firearm in light of jurisprudence which asserts that in
order for the same to be considered, adequate proof, such as written or testimonial evidence, must be
presented showing that the appellant was not a licensed firearm holder. There was no such proof in
the case at bar.