People v Judge Ayson; G.R. No. 85215; 07 Jul 1989; 175 SCRA 216

FACTS:
Felipe Ramos, a ticket freight clerk of the Philippine Airlines (PAL), was charged with estafa for irregularities in the sale 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 where he admitted to the offense.

ISSUE(S):
Whether or not respondent judge is correct in not admitting the note and statement in evidence.

RULING:
NO. Felipe Ramos was not in any sense under custodial interrogation prior to and during the administrative inquiry into the discovered irregularities in ticket sales in which he appeared to have had a hand. The constitutional rights of a person under custodial interrogation under Section 20, Article IV of the 1973 Constitution did not therefore come into play. He had voluntarily answered questions posed to him on the first day of the administrative investigation and agreed that the proceedings should be recorded. The note that he sent to his superiors offering to compromise his liability in the alleged irregularities, was a free and even spontaneous act on his part.

Petition is GRANTED. Respondent judge ordered to ADMIT IN EVIDENCE the note and statement.

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Category: Legal Chyme

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