PEOPLE VS AYSON, 175 SCRA 216

Rule 115: Rights of the Accused

Facts:

Private respondent Felipe Ramos was a ticket freight clerk of the Philippine Airlines (PAL), assigned at its
Baguio City station. He was allegedly involved in irregularities in the sales of plane tickets, hence the PAL
management conducted an investigation in accordance with PAL's Code of Conduct and Discipline, and the
Collective Bargaining Agreement. On the day before the investigation Ramos gave to his superiors a
handwritten notes stating his willingness to settle the irregularities allegedly charged amounting to Php 76,
000.00. While on investigation, Ramos confessed that he had misused the proceeds of the tickets and he had
planned on paying back the money. Two months after, a crime of estafa was filed against him. Ramos pleaded
not guilty. While on the presentation of evidence, private prosecutors made a written offer of evidence which
were marked as Exhibit A which was the statement of Ramos and exhibit K as his handwritten admission,
however the defendant counsel refuted and said that the document were confessions and were taken without
the accused being represented by a lawyer. The respondent judge rejected the exhibits A and K being
inadmissible evidence, since it does not appear that the accused was reminded of his constitutional rights to
remain silent and to have counsel, and that when he waived the same and gave his statement, it was with the
assistance actually of a counsel. The private prosecutors filed a motion for reconsideration however denied,
hence this appeal. 9

Issue:

Whether the respondent judge acted with grave abuse of discretion to have excluded the People's Exhibits A
and K?

Held:

Yes, respondent judge acted with grave abuse of discretion to have excluded the People's Exhibits A and K. It
seems quite evident that a defendant 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 on the first day of the administrative investigation.

Hence, the constitutional rights of a person under custodial interrogation, Section 20, Article IV of the 1973
Constitution did not therefore come into play, were of no relevance to the inquiry.

Rights of the accused was laid down in Miranda v. Arizona, Section 20 states that whenever any person is
"under investigation for the commission of an offense":
 1) he shall have the right to remain silent and to counsel, and to be informed of such right, 21

2) nor force, violence, threat, intimidation, or any other means which vitiates the free will shall
be used against him; and
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3) any confession obtained in violation of x x (these rights shall be inadmissible in evidence. 23

Under the Rules of Court, in all criminal prosecutions the defendant is entitled among others-

1) to be exempt from being a witness against himself, and 2) to testify as witness in his own behalf; but if he
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offers himself as a witness he may be cross-examined as any other witness; however, his neglect or refusal to
be a witness shall not in any manner prejudice or be used against him.