Case Digest (G.R. No. 85215) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In The People of the Philippines vs. Hon. Judge Ruben Ayson and Felipe Ramos, G.R. No. 85215, decided July 7, 1989 under the 1973 Constitution, the petitioner, the People of the Philippines, assails orders of Branch 6 of the Regional Trial Court in Baguio City excluding two prosecution exhibits in a criminal estafa case. Felipe Ramos, a ticket freight clerk of Philippine Airlines (PAL) at Baguio, was informed on February 9, 1986 of an administrative investigation into alleged irregularities amounting to ₱76,000. The day before, he submitted a handwritten compromise offer (later marked Exhibit K). At the PAL inquiry, he answered questions that were reduced to writing (later marked Exhibit A). No Miranda‐type warnings were given. Subsequently, an information for estafa was filed, and at trial the private prosecutors offered Exhibits A and K. Judge Ayson admitted all other evidence but, on August 9, 1988, excluded Exhibits A and K for failure to inform Ramos of his rights to remain Case Digest (G.R. No. 85215) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background
- Felipe Ramos, ticket freight clerk at Philippine Airlines (PAL) Baguio station, was implicated in irregularities in ticket sales. PAL management, pursuant to its Code of Conduct and the PALEA Collective Bargaining Agreement, scheduled an administrative investigation for February 9, 1986.
- On February 8, 1986, Ramos submitted a handwritten note (later marked Exhibit K) offering to settle the alleged liability of approximately ₱76,000 subject to PAL‐imposed conditions by 1700H of February 9.
- Administrative Inquiry and Criminal Case
- On February 9, 1986, PAL Branch Manager Edgardo R. Cruz, with Station Agent Antonio Ocampo, Ticket Clerk Rodolfo Quitasol, and PALEA Shop Steward Cristeta Domingo, conducted the inquiry. Ramos was informed of audit findings, answered Cruz’s questions, and signed a written statement (marked Exhibit A). He received no advisement of rights to remain silent or to counsel.
- No compromise was reached. Approximately two months later, the People of the Philippines filed an information charging Ramos with estafa involving ₱76,700.65, allegedly committed between March 12, 1985 and January 29, 1986. Ramos pleaded “Not Guilty” and trial ensued under PAL lawyers and the Fiscal’s supervision.
- At the close of the prosecution’s case (June 21, 1988), Exhibits A (the February 9 statement) and K (the February 8 note) were offered. Defense counsel objected, arguing Ramos had not been informed of constitutional rights nor assisted by counsel.
- By Orders dated August 9 and September 14, 1988, RTC Branch 6 Judge Ruben Ayson excluded Exhibits A and K, holding that Ramos should have been reminded of his Miranda‐type rights and that any waiver required counsel’s presence and writing.
- The People (through private prosecutors) filed a certiorari petition in the Supreme Court. On October 26, 1988, the Court issued a Temporary Restraining Order enjoining further proceedings. The Solicitor General subsequently filed comments supporting the petitioner.
Issues:
- Did Judge Ayson commit grave abuse of discretion by excluding Exhibits A and K on the ground that Ramos was not advised of the right to remain silent and to counsel during an administrative investigation?
- Whether Ramos’s participation in the PAL administrative inquiry constituted custodial interrogation triggering the Miranda‐type safeguards of Section 20, Article IV of the 1973 Constitution.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)