Case Summary (G.R. No. 85215)
Petitioner
The People of the Philippines, represented by PAL’s lawyers under Fiscal supervision and the Solicitor General.
Respondent
Hon. Judge Ruben Aksyon, Branch 6, Regional Trial Court, Baguio City; and private respondent Felipe Ramos.
Key Dates
• February 8–9, 1986: Ramos offers written compromise and participates in an administrative inquiry.
• March 12, 1986–January 29, 1986: Period covered by the estafa information.
• June 21, 1988: Prosecution tenders Ramos’s February 1986 statements as Exhibits A and K.
• August 9 & September 14, 1988: RTC excludes Exhibits A and K for lack of Miranda warnings.
• July 7, 1989: Supreme Court decision.
Applicable Law
1987 Constitution, Article III:
• Section 17 – right against self-incrimination.
• Section 12 – rights during custodial interrogation (silence, counsel, informed in writing in presence of counsel).
Administrative Inquiry and Ramos’s Admissions
PAL management, acting under its Code of Conduct and collective bargaining agreement, summoned Ramos for a February 9, 1986 inquiry. On February 8 he submitted a handwritten note offering to settle P76,000 in alleged ticket irregularities. At the next day’s investigatory meeting, conducted by the PAL Branch Manager, Ramos answered questions in writing—denying disclosure of tickets, admitting misapplication of proceeds, proposing staggered repayment, and requesting union representation.
Criminal Prosecution and Evidence
Two months later, the Fiscal filed an estafa information charging Ramos with misappropriation of P76,700.65 in ticket proceeds. At trial, the People offered Exhibits A (Ramos’s February 9 statement) and K (February 8 note). Defense filed objections, arguing Ramos had not been advised of his right to remain silent or to counsel at an “inquiry” lacking Miranda warnings.
RTC’s Exclusion of Exhibits
Judge Aksyon, citing the 1973 Constitution’s Section 20, Article IV (right against self-incrimination and rights in custodial investigation), ruled Ramos’s statements inadmissible because he was neither informed of nor waived his rights to silence and counsel in writing with counsel present. A motion for reconsideration was denied.
Petition for Certiorari
The People, joined by the Solicitor General, sought certiorari to annul the exclusion orders. The Supreme Court issued a TRO restraining further trial and called for comments from all parties.
Right Against Self-Incrimination under Section 17, Art. III
Every witness, voluntary or subpoenaed, may refuse to answer specific incriminating questions. The right must be claimed at the time the question is posed; it does not excuse non-appearance or blanket refusal to testify. No affirmative duty exists for a judge to warn a non-suspect witness of this right.
Rights in Custodial Interrogation under Section 12, Art. III
Miranda-type safeguards—right to remain silent, to counsel, to be informed of these rights in writing before counsel, and prohibition of coercion—apply only when a person is in police custody or significantly deprived of liberty and under investigation for
Case Syllabus (G.R. No. 85215)
Facts of the Case
- Private respondent Felipe Ramos was a ticket freight clerk at Philippine Airlines (PAL) Baguio City station, suspected of irregularities in ticket sales.
- PAL management, invoking its Code of Conduct and Discipline under the Collective Bargaining Agreement with PALEA, scheduled an administrative investigation on February 9, 1986.
- On February 8, 1986, Ramos handed his superiors a handwritten note offering to settle alleged irregularities amounting to approximately P76,000 by February 9.
- During the February 9 inquiry, conducted by Branch Manager Edgardo R. Cruz and witnessed by PAL officers and a PALEA stewardess, Ramos was informed of the Audit Team’s findings and his answers were taken down in writing (later marked Exhibit A).
- No settlement was reached. Two months later, an information for estafa was filed charging Ramos with misappropriating or converting P76,700.65 in ticket proceeds between March 12, 1985 and January 29, 1986.
- At arraignment, Ramos pleaded not guilty and the People’s case proceeded to trial.
Procedural History
- The prosecution offered as evidence:
• Exhibit A – Ramos’s written administrative statement dated February 9, 1986.
• Exhibit K – Ramos’s handwritten note of February 8, 1986. - Defense counsel objected, arguing Ramos was not informed of his right to remain silent or to have counsel.
- By Order of August 9, 1988, RTC Judge Ruben Ayson excluded Exhibits A and K for lack of constitutional warnings and counsel assistance.
- A motion for reconsideration was denied on September 14, 1988.
- Private prosecutors, in the name of the People, filed a petition for certiorari and prohibition before the Supreme Court, assailing those exclusionary orders.
- The Supreme Court issued a Temporary Restraining Order on October 26, 1988, enj