Case No.

1193
SANTOS v. SANDIGANBAYAN
G.R. No. 71523-25
December 8, 2000
FACTS OF THE CASE
In the three consolidated cases at bar, the petitioners herein were charged with estafa through falsification
of public documents. The Sandiganbayan filed the information against the petitioners-accused alleging that
the latter were able to acquire 9 million pesos from their scheme. As found out by the Supreme Court, the
accused were able to infiltrate the Clearing Center of the Central Bank of the Philippines through different
bank accounts in different banks. These were termed as the switching and pilferage schemes. These schemes
also made use of their positions as employees of such banks in order to accomplish the same.
Subsequently, in an operation of the National Bureau of Investigation, they were taken into custody for
investigation and interrogation. According to the prosecution, petitioners-accused knowingly waived their
right to counsel and right to remain silent. As evidenced by a document, signed by petitioners, entitled
WAIVER, the prosecution alleged that the statements made by the petitioners were done with full consent
and knowledge of the waiver of their constitutional rights. Further, they alleged that the accused were fully
informed of their constitutional right to remain silent and right to counsel.
ISSUE/S
Whether or not the statements made by the accused are admissible in evidence and that the waiver of right
is a valid waiver of said right
HELD/RATIO
The Supreme Court ruled that, [t]he statements were intelligently executed is borne out by the fact that
both confessants have reached the tertiary level of education: Valentino holds the degree of Bachelor of
Science in Commerce while petitioner Estacio reached the first year of college education in banking and
finance. Possessed with sufficient education and not proven to be mentally unfit, they could have protested
the forced extraction of culpability from themselves if indeed that was true.
Moreover, the extrajudicial confessions in question are replete with details on the manner in which the
crimes were committed, thereby ruling out the probability that these were involuntarily made.
Voluntariness of a confession may be inferred from its language such that, if upon its face the
confession exhibits no sign of suspicious circumstances tending to cast doubt upon its integrity, it
being replete with details which could possibly be supplied only by the accused reflecting spontaneity and
coherence which, psychologically, cannot be associated with a mind to which violence and torture have
been applied, it may be considered voluntary.

Prepared by: Antonio Dominic G. Salvador