You are on page 1of 1

People v Ramos 122 SCRA 312 FACTS: Malcon Olevere was arrested during the routine patrol of P/Lt.

Mediavillo and P/Sgt. Linga, looking suspicious the police officers identify themselves, stopped and frisked the suspect and found in his possesion dried marijuana leaves. Upon investigation, Olevere declared that he bought the recovered marijuana leaves from Rogelio Ramos. The following day a police team with the suspect Olevere went to the residence of appellant Rogelio Ramos and arrested him. During the custodial investigation, Olevere executed a written sworn statement implicating the accused-appellant as the source of the marijuana leaves. The accused, after having been apprised of his constitutional rights, verbally admitted before Lt. Mediavillo and P/Sgt. Linga the commission of the offense charged. Upon arraignment, Ramos pleaded not guilty to the information. At the trial, the prosecution presented three witnesses. After trial the court of First Instance found the accused-appellant guilty beyond reasonable doubt of the crime charged in view of the verbal admission given by the appellant himself and the evidence offered and admitted in court. The case was now in the SC for its automatic review. ISSUE: Whether the appraisal of the accused constitutional rights during the custodial investigation was sufficiently exercised. Ruling: Although the records prove that the appellant has been duly apprised of his constitutional rights to silence and to counsel, the Court was not fully convinced that this appraisal was sufficiently manifested and intellegently understood and accepted by the appellant Ramos. This is fatal to the admissibility of appellants verbal admission. The court have repeatedly emphasized that care should be taken in accepting extra-judicial admission, especially when taken during custodial investigation. Appellant has only finished Grade VI, which means that he is not adequately educated to understand fairly and fully the significance of his constitutional rights to silence and to counsel. As mandated, it is not enough that the police investigators merely informs him of his constitutional rights to silence and to counsel, and then taking his statements down, the interrogating officer must have patience explaining these rights to him. The records did not reveal that these requirements have been fully complied with, nor was there any showing that appellant has been represented by counsel during investigation. The court hold that the verbal admission of appellant during custodial investigation may not be taken in evidence against him.

You might also like