Case No.

1273
GALMAN v. PAMARAN
G.R. No. 71208-09
August 30, 1985
FACTS OF THE CASE
The case at bar revolves around the event that change the course of history of the Philippines when senator
Benigno Ninoy Aquino was shot on the tarmac of the Manila International Airport after his plane arrived
from the United States. In order to conduct an independent and thorough investigation on the matter, P.D.
1886 was enacted, also known as the Agrava Board. The board was ordered to conduct public hearings
wherein testimonies of witnesses were admitted as evidence for and against the prosecution of the herein
private respondents. Upon the termination of the investigation, the findings were then submitted to the
President. These were then forwarded to the Tanodbayan which filed an information of murder of (1) Sen.
Ninoy Aquino, and (2) Rolando Galman against herein respondents, charged as principals, accessories and
accomplices.
Upon arraignment, respondents pleaded not guilty. During trial, private respondent Ver alleged that the
testimonies of the accused would be violative of their right to self-incrimination and the immunity granted
by P.D. 1886. On the other hand, petitioner Tanodbayan argued that the right to self-incrimination cannot
be invoked by herein respondents in view of the failure of respondents to invoke the same during the
investigation of the Board. However, despite these contentions the Sandiganbayan issued their resolutions
exempting the testimonies of private respondents as evidence. Hence the petition.
ISSUE/S
Whether or not the extra-judicial confessions of private respondents were admissible in evidence in lieu of
P.D. 1886.
HELD/RATIO
According to the Supreme Court, [i]t is true a person in custody undergoing investigation labors under a
more formidable ordeal and graver trying conditions than one who is at liberty while being investigated.
But the common denominator in both which is sought to be avoided is the evil of extorting from the very
mouth of the person undergoing interrogation for the commission of an offense, the very evidence with
which to prosecute and thereafter convict him. This is the lamentable situation we have at hand.
In the case at bar, the Court ruled that the Agrava Board called upon the private respondents not only to
elicit surrounding facts and circumstances. They were made to witness against themselves, under the
compulsion of the media, international pressures, and other external circumstances. Taking into
consideration the constitutional provisions on the right to self-incrimination, the evidence gathered from
the private respondents herein are inadmissible as evidence, as rightly pointed out by the Sandiganbayan.

Prepared by: Antonio Dominic G. Salvador