This case has been cited 1 times or more.
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2003-04-04 |
QUISUMBING, J. |
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| In this case, it cannot be said that the waiver of the right to counsel was made knowingly and intelligently. Appellant Joel Janson was illiterate, and a minor of sixteen (16) years at the time of the offense. As held in the case of People v. Bonola,[47] where the accused was unschooled and only nineteen (19) years old when arrested, it is difficult to believe that considering the circumstances, the accused made an intelligent waiver of his right to counsel. In such instances, the need for counsel is more pronounced. | |||||