Consti-2 - Digest - 251 - People VS Judge Ayson

You might also like

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 1

CONSTI-2 SLC-LAW

DIGEST 251: PEOPLE VS JUDGE AYSON


TOPIC: Right under Custodial Investigation

G.R. No. 85215 July 7, 1989

PETITIONER: The People Of The Philippines


RESPONDENTS: Hon. Judge Ruben Ayson, Presiding Over Branch 6, Regional Trial Court, First Judicial Region,
Baguio City, And Felipe Ramos

FACTS:

Private respondent Felipe Ramos was a ticket freight clerk of the Philippine Airlines (PAL) who was charged with
estafa for irregularities in the sales of plane tickets.

Respondent judge admitted all evidentiary and testamentary evidence offered against Ramos except for the
latter’s handwritten note expressing his willingness to settle the irregularities alleged against him as well as his
statement during an administrative investigation wherein he admitted to the offense.

ISSUE:

 Whether or not the Respondent Judge is correct in not admitting the note and the statement in evidence.

HELD:

No, the Respondent Judge is not correct in not admitting the note and the statement in evidence.

The right in custodial interrogations is meant "questioning initiated by law enforcement officers after a person
has been taken into custody or otherwise deprived of his freedom of action in any significant way.

It is clear from the undisputed facts of this case that Felipe Ramos was not in any sense under custodial
interrogation, as the term should be properly understood, prior to and during the administrative inquiry into the
discovered irregularities in ticket sales in which he appeared to have had a hand. It is also clear, too, that Ramos had
voluntarily answered questions posed to him and agreed that the proceedings should be recorded. The note that he sent
to his superiors on the day before the investigation, offering to compromise his liability in the alleged irregularities, was
a free and even spontaneous act on his part.

Not every statement made to the police by a person involved in some crime is within the scope of the
constitutional protection. If not made "under custodial interrogation," or "under investigation for the commission of an
offense," the statement is not protected.

Respondent Judge ordered to admit in evidence the note and statement.

Page 1 of 1 © ALICE O. LEDAMA

You might also like