People v Judge Ayson , G.R. No.

85215, July 7, 1989

Facts: Felipe Ramos was a ticket freight clerk of the Philippine Airlines and was allegedly involved in
irregularities in the sales of plane tickets. The PAL management notified him of an investigation to be
conducted. That investigation was scheduled in accordance with PAL's Code of Conduct and Discipline,
and the Collective Bargaining Agreement signed by it with the Philippine Airlines Employees' Association
(PALEA) to which Ramos pertained. A letter was sent by Ramos stating his willingness to settle the
amount of P76,000. The findings of the Audit team were given to him, and he refuted that he misused
proceeds of tickets also stating that he was prevented from settling said amounts. He proffered a
compromise however this did not ensue. Two months after a crime of estafa was charged against
Ramos. Ramos pleaded not guilty. Evidence by the prosecution contained Ramos’ written admission and
statement, to which defendants argued that the confession was taken without the accused being
represented by a lawyer. Respondent Judge did not admit those stating that accused was not reminded
of his constitutional rights to remain silent and to have counsel. A motion for reconsideration filed by
the prosecutors was denied. Hence, this appeal.

Issue: Whether or Not the respondent Judge correct in making inadmissible as evidence the admission
and statement of accused.

Ruling: NO. The judge should admit the evidence in court as the accused was not under custodial
investigation when his statements were taken. One cannot invoke violation of the right to counsel in
administrative proceeding. The right to self-incrimination and custodial investigation are accorded only
when the accused is subjected to custodial inquest which involves the questioning initiated by police
authorities after a person is taken in custody or deprived of his freedom in any way. Because the
statements were obtained beyond the purview of custodial investigation the evidence should be
admitted in court.