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PEOPLE v. ALFREDO ENANORIA

This case has been cited 1 times or more.

2004-03-09
YNARES-SATIAGO, J.
In People v. Pia,[30] we held that "where appellants did not present evidence of compulsion or duress or violence on their persons; where they failed to complain to officers who administered the oaths; where they did not institute any criminal or administrative action against their alleged maltreatment; where there appears no marks of violence on their bodies and where they did not have themselves examined by a reputable physician to buttress their claim, all these should be considered as factors indicating voluntariness of confessions." The failure of the appellant to complain to the swearing officer or to file charges against the persons who allegedly maltreated him, although he had all the chances to do so, manifests voluntariness in the execution of his confessions.[31] To hold otherwise is to facilitate the retraction of his statements at the mere allegation of threat, torture, coercion, intimidation or inducement, without any proof whatsoever. People v. Enanoria further declared that another indicium of voluntariness is the disclosure of details in the confession which could have been known only to the declarant.[32]