Case Digest (G.R. No. 32025) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Francisco Beltran v. Felix Samson, Judge of the Second Judicial District, and Francisco Jose, Provincial Fiscal of Isabela (G.R. No. 32025, September 23, 1929), petitioner Beltran, then Municipal Treasurer of a town in Isabela, was ordered by Judge Samson, upon motion of Fiscal Jose, to appear before the fiscal and take dictation in his own handwriting. The purpose was to compare his handwriting with certain documents alleged to be falsified. The lower court relied on Section 1687 of the Administrative Code and decisions such as People v. Badilla (48 Phil. 718), United States v. Tan Teng (23 Phil. 145), United States v. Ong Siu Hong (36 Phil. 735), and Villaflor v. Summers (41 Phil. 62) to justify compelling witnesses to attend preliminary investigations. Beltran refused, invoking the privilege against self-incrimination under paragraph 3, section 3 of the Jones Law, incorporated in General Orders No. 58, and sought a writ of prohibition to prevent enforcement of the order. Case Digest (G.R. No. 32025) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Lower Court Proceedings
- Francisco Beltran (petitioner) was ordered by Judge Felix Samson to appear before Provincial Fiscal Francisco Jose.
- The order, based on Administrative Code § 1687, required Beltran to take dictation in his own handwriting for the purpose of comparing it with writings alleged to be falsified.
- Contentions of the Parties
- Respondents argued that the order was lawful under:
- Section 1687 of the Administrative Code (compelling witnesses at a criminal investigation).
- Established Philippine and U.S. jurisprudence (People v. Badilla, U.S. v. Tan Teng, U.S. v. Ong Siu Hong, Villaflor v. Summers).
- Petitioner contended that the order violated the privilege against self-incrimination guaranteed by the Jones Law (paragraph 3, section 3) and incorporated in General Orders No. 58, §§ 15(4) and 56.
Issues:
- Does compelling a person to furnish a handwriting sample during a criminal investigation constitute compelling him “to be a witness against himself” under the constitutional privilege against self-incrimination?
- Is the privilege against self-incrimination limited to oral testimony, or does it extend to testimonial acts (such as writing) that create new evidence?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)