Title
Beltran vs. Samson
Case
G.R. No. 32025
Decision Date
Sep 23, 1929
Petitioner challenged a court order requiring him to write under dictation for handwriting comparison, invoking his constitutional right against self-incrimination. The Supreme Court ruled in his favor, holding that compelled writing is a testimonial act protected under the privilege against self-incrimination.
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Case Digest (G.R. No. 32025)

Facts:

  1. Parties Involved:

    • Petitioner: Francisco Beltran
    • Respondents: Felix Samson (Judge of the Second Judicial District) and Francisco Jose (Provincial Fiscal of Isabela)
  2. Nature of the Case:

    • The petitioner filed a petition for a writ of prohibition against the respondents.
  3. Key Allegations:

    • The respondent judge ordered the petitioner to appear before the provincial fiscal to take dictation in his own handwriting.
    • The purpose of the order was to compare the petitioner's handwriting with certain documents suspected of being falsified.
    • The petitioner refused to comply, invoking his constitutional right against self-incrimination under the Jones Law and General Orders, No. 58.
  4. Legal Basis for the Order:

    • The respondents relied on Section 1687 of the Administrative Code, which allows the fiscal and the judge to compel witnesses to appear during the investigation of a crime.
    • They cited precedents such as People vs. Badilla, United States vs. Tan Teng, United States vs. Ong Siu Hong, and Villaflor vs. Summers.
  5. Constitutional Issue:

    • The petitioner argued that the order violated his constitutional right not to be compelled to be a witness against himself.

Issue:

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Ruling:

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Ratio:

  1. Scope of the Constitutional Privilege:

    • The constitutional right against self-incrimination is not limited to oral testimony but extends to all forms of evidence, including the act of writing.
    • The privilege protects individuals from being compelled to create evidence that may incriminate them.
  2. Testimonial Nature of Writing:

    • Writing is not a purely mechanical act; it involves the application of intelligence and attention, making it a testimonial act.
    • Compelling the petitioner to write under dictation would require him to furnish evidence that could identify him as the falsifier, which is prohibited by the constitution.
  3. Distinction from Voluntary Acts:

    • Cases where defendants voluntarily provided handwriting samples or other evidence are not applicable, as the petitioner in this case refused to comply and invoked his constitutional rights.
  4. Protection of Innocent Persons:

    • The constitutional privilege exists to protect innocent individuals from being compelled to furnish evidence against themselves, even if it may result in some criminals evading justice.
  5. Precedents Distinguished:

    • The Court distinguished the case from People vs. Badilla, United States vs. Tan Teng, United States vs. Ong Siu Hong, and Villaflor vs. Summers, noting that in those cases, the defendants either voluntarily complied or the evidence sought was already in existence.


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