PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs.

JOSE ENCARNACION
MALIMIT alias "MANOLO", accused-appellant.

FACTS: Jose Encarnacion Malimit, charged with and convicted of the special complex crime of robbery with
homicide. Edilberto Batin (houseboy of Onofre Malaki) saw appellant Jose Malimit rushing out through the
front door of Malaki’s store while his boss,blood was sprawled on the floor "struggling for his life". On the
other hand, Florencio Rondon, a farmer, who arrived at the store to purchase chemical for his rice land saw the
appellant rushing out the front door of Malaki’s store with a blood stained bolo. Batin met Rondon outside the
store and rushed to the house of Malaki’s brother-in-law Eutiquio Beloy and informed Beloy of the tragic
incident which befell Malaki. They went back to the store and saw the lifeless body of Malaki. Beloy noticed
that the store's drawer was opened and ransacked and the wallet of Malaki was missing from his pocket. Thus,
this appeal. In his appeal, appellant’s ask for his acquittal

ISSUE: Whether or not, the admission as evidence of Malaki's wallet together with its contents violates his
right against self-incrimination.?

RULING: The right against self-incrimination guaranteed under our fundamental law finds no application in
the case. This right, is a prohibition of the use of physical or moral compulsion, to extort communications from
him . It is simply a prohibition against legal process to extract from the accused’s own lips, against his will,
admission of his guilt. It does not apply to the instant case where the evidence sought to be excluded is not an
incriminating statement but an object evidence.

These are the so-called "Miranda rights" so oftenly disregarded by our men in uniform. However, infractions in
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. Concededly, appellant was not informed of his right to remain silent and to have his own counsel
by the investigating policemen during the custodial investigation. Neither did he execute a written waiver of
these rights in accordance with the constitutional prescriptions. Nevertheless, these constitutional short-cuts do
not affect the admissibility of Malaki's wallet, identification card, residence certificate and keys for the purpose
of establishing other facts relevant to the crime. Thus, the wallet is admissible to establish the fact that it was
the very wallet taken from Malaki on the night of the robbery. The identification card, residence certificate and
keys found inside the wallet, on the other hand, are admissible to prove that the wallet really belongs to Malaki.
Furthermore, even assuming arguendo that these pieces of evidence are inadmissible, the same will not detract
from appellant's culpability considering the existence of other evidence and circumstances establishing
appellant's identity and guilt as perpetrator of the crime charged.

We ruled that there can be a verdict of conviction based on circumstantial evidence when the circumstances
proved form an unbroken chain which leads to a fair and reasonable conclusion pinpointing the accused, to the
exclusion of all the others, as the perpetrator of the crime. In this case, there were at least five (5)
circumstances constituting an unbroken chain of events which by their "concordant combination and
cumulative effect", satisfy the requirements for the conviction of the appellant,

The Court affirmed the judgment of conviction.