This case has been cited 5 times or more.
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2011-10-19 |
DEL CASTILLO, J. |
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| Infraction of the rights of an accused during custodial investigation or the so-called Miranda Rights render inadmissible only the extrajudicial confession or admission made during such investigation.[1] "The admissibility of other evidence, provided they are relevant to the issue and is not otherwise excluded by law or rules, is not affected even if obtained or taken in the course of custodial investigation."[2] | |||||
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2008-09-29 |
TINGA, J. |
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| The RTC and the Court of Appeals correctly gave credence to Helen's explanation on the two-week delay in reporting the identity of the assailants in the killing of Eduardo. It is understandable that she was still reeling from extreme shock and grief due to the unexpected and gruesome death of Eduardo. In People v. Lapay,[50] we held that "delay in revealing the names of the malefactors does not, by itself, impair the credibility of the prosecution witnesses and their testimonies." Time and again, this Court has ruled that "the nondisclosure by the witness to the police officers of [accused-appellant's] identity immediately after the occurrence of the crime is not entirely against human experience."[51] It is already of judicial notice that family members of victims of violent crimes react to an unnatural occurrence in diverse ways. Some, if they have any information about the incident, would waste no time in telling the police everything they know. Others would rather choose, or are forced, to clam up and refuse to divulge any information they may possess. And then, there are the majority of family members who would first hesitate before they reveal what they know.[52] | |||||
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2008-06-25 |
VELASCO JR., J. |
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| Moreover, while we hold in this case that petitioner's Miranda rights were not violated, still we will not be remiss to reiterate what we held in People v. Malimit that the infractions of the so-called Miranda rights render inadmissible "only the extrajudicial confession or admission made during custodial investigation. The admissibility of other evidence, provided they are relevant to the issue and is not otherwise excluded by law or rules, is not affected even if obtained or taken in the course of custodial investigation."[16] An admission is an act, declaration or omission of a party as to a relevant fact,[17] while confession is a declaration of an accused acknowledging his guilt of the offense charged, or of any offense necessarily included therein.[18] | |||||
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2005-09-16 |
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| . . . The State having the right to declare what acts are criminal, within certain well defined limitations, has a right to specify what act or acts shall constitute a crime, as well as what proof shall constitute prima facie evidence of guilt, and then to put upon the defendant the burden of showing that such act or acts are innocent and are not committed with any criminal intent or intention.[44] The constitutional assurance of the right against self incrimination likewise cannot be invoked by petitioners. The right is a prohibition against the use of physical or moral compulsion to extort communications from the accused. It is simply a prohibition against legal process to extract from the accused's own lips, against his will, admission of his guilt.[45] In this case, petitioners are not compelled to present themselves as witnesses in rebutting the presumption established by law. They may present documents evidencing the purported bank loans, money market placements and other fund sources in their defense. | |||||
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2000-05-31 |
BELLOSILLO, J. |
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| The trial court observed the demeanor of the witnesses for the prosecution and for the defense, and believed the former whose testimonies were candid, straightforward and bore the earmarks of truth while characterizing the latter as preposterous and unbelievable.[16] In criminal jurisprudence, when the issue is one of credibility of witnesses, appellate courts will not disturb the findings of the trial court[17] and the Court will respect these findings considering that the trial court is in a better position to decide the question, having heard the witnesses themselves and observed their deportment and manner of testifying during the trial.[18] Of course, the rule admits of certain exceptions: (a) when patent inconsistencies in the statement of witnesses are ignored by the trial court, or (b) when the conclusions arrived at are clearly unsupported by the evidence.[19] But in this case, neither exception can be found, and the Court is not precluded from making its own assessment of the probative value of the testimony of the witnesses on the basis of the transcript of stenographic notes thereof.[20] We have carefully reviewed the records and found no reason to deviate from the conclusions drawn by the trial court; hence, they must prevail. | |||||