Facts:
Private respondent Felipe Ramos, a ticket freight clerk of the Philippine Airlines, was charged with having unlawfully kept for himself the proceeds of the sale of plane tickets. Management informed him of the investigation to be conducted. Prior to the investigation, he informed management in writing of his willingness to settle the irregularities. At the investigation, Felipe’s answers in response to questions were taken down in writing. An information for estafa was filed later. During trial, the written offer of evidence included statement of the accused and his handwritten admission. The trial judge excluded the said evidence since it does not appear that the accused was reminded of this constitutional rights to remain silent and to have counsel. The written admission was also made without the assistance of a counsel.
Held:
The rights to which respondent Judge has given a construction exist only in "custodial interrogations," or "in-custody interrogation of accused persons." By custodial interrogation is meant "questioning initiated by law enforcement officers after a person has been taken into custody or otherwise deprived of his freedom of action in any significant way."
Felipe was not in any sense under custodial interrogation prior to and during the administrative inquiry into the discovered irregularities in ticket sales. Thus, the statement or confession voluntarily given by him during the administrative investigation, that he had malversed his employer's funds is admissible although without a prior information of his rights under Article III, Section 12 of the Constitution and without assistance of counsel.
Citation: People of the Philippines vs Judge Ruben Ayson, G.R. No. 85215 July 7, 1989
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