PEOPLE vs.

CABILES

Facts:
Appellant was convicted of Robbery with Rape & was sentenced to
suffer imprisonment of Reclusion Perpetua. It was alleged that
appellant entered into the house of one Marites Atienza to rob but
later on raped the house helper of Marites, Luzviminda. Information
was filed against him w/c led to his arrest at the sash factory where
he was working. He was found sleeping on a bench wearing the
bracelet of Marites which was allegedly among those taken by the
robbers. PO went inside the factory building and found a plastic bag
containing a womans undershirt, a light blue shirt & a wristwatch
w/ a brand name Chanel. The following day, Marites saw appellant
at the Police Station & admitted his guilt & pointed to Jaime
Mabingnay as the mastermind. During the trial, Marites testified
against appellant based on the extrajudicial admission.

Issue: W/N the extrajudicial admission made by appellant to Marites
is admissible as evidence?

Held: YES!

The confession made by appellant to Marites was admissible as
evidence but the written confession was inadmissible. The written
admission was clearly w/out the assistance of counsel and is
therefore inadmissible. However, the constitutional procedures on
custodial investigation do not apply to spontaneous statement, not
elicited through questioning by authorities, but given in an ordinary
manner whereby the accused orally admitted having committed the
crime as in the case at bar.