Title
Magtoto vs. Manguera
Case
G.R. No. L-37201-02
Decision Date
Mar 3, 1975
The 1973 Philippine Constitution's custodial rights apply prospectively; confessions obtained before its effectivity remain admissible despite lack of rights advisement.
A

Case Digest (G.R. No. L-37201-02)

Facts:

  • Parties and Cases
    • G.R. Nos. L-37201-02 (March 3, 1975) – Clemente Magtoto v. Judge Miguel M. Manguera et al., Criminal Cases Nos. 394-395, CFI Occidental Mindoro (murder of Ignacio and Eduardo Calara).
    • G.R. No. L-37424 (March 3, 1975) – Maximo Simeon et al. v. Judge Onofre A. Villaluz et al., Criminal Case No. CCC-VII-87, Pasig, Rizal (murder of Pedro Langaoen).
    • G.R. No. L-38929 (March 3, 1975) – People of the Philippines v. Judge Asaali S. Isnani et al., Criminal Case No. 4113, CFI Zamboanga del Sur (robbery with homicide).
  • Confessions and Trial Court Orders
    • Magtoto – Extrajudicial confession dated November 15, 1972; admitted in evidence on June 18, 1973 despite objection that he was not informed of right to counsel/silence.
    • Simeon et al. – Extrajudicial confessions dated October 17, 1970; admitted on August 16, 1973 without counsel during custodial interrogation.
    • People v. Isnani – Confessions dated November 7, 1968 and September 1, 1970; rejected June 18, 1974 for failure to inform of right to counsel/silence.

Issues:

  • Constitutional Scope
    • Does Section 20, Article IV of the 1973 Constitution bar the admission of any confession obtained from a person under investigation who has not been informed of the right to remain silent and to counsel?
  • Temporal Application
    • Should the exclusionary rule of Section 20 (inadmissibility of such confessions) apply prospectively only or also to confessions taken before the Constitution’s effectivity (January 17, 1973)?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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