Rights of Suspects under Custodial Investigation

3. Admissibility – ‘’ Fruit of the Poisonous Tree’’

Confession given to Municipal Mayor

People vs. Andan

Facts:

 About 4:00 P.M., in Concepcion Subdivision, Baliuag, Bulacan, Marianne Guevarra,

twenty years of age and a second-year student at the Fatima School of Nursing was
walking along the subdivision when appellant invited her inside his house under the
pretext of asking favour that the blood pressure of his grandmother should be taken.
 Upon entering the house, nobody is there and suddenly Marianne was punched in
the abdomen and brought to kitchen where she was raped.
 Afterwards, her unconscious body was dragged and left to an old toilet until dark
 Night came and appellant draped the girl’s body over the fence to transfer it to the
vacant lot where he hit her head and face with a piece of concrete block. He then
dragged it to a shallow portion of the lot and abandoned it.
 This prompted Mayor Cornelio Trinidad of Baliuag to form a crack team of police
officers to look for the criminal where they located and arrested him on his parent’s
house.
 He was brought to the headquarters where he only admit being a lookout and that
his neighbors, Larin and dizon were the one who killed the girl
 Appellant and the two suspects were brought back to the police headquarters. The
following day, a physical examination was conducted on the suspects.
 Media representatives were already gathered at the police headquarters awaiting
the results of the investigation.
 Mayor Trinidad arrived and proceeded to the investigation room where he was
suddenly approached by the appellant and whispered a request that they talk
privately.
 The mayor led appellant to the office of the Chief of Police and there, appellant
broke down and confessed his guilt the afterwards open the door and let the media
witness the confession.
 On arraignment, however, appellant entered a plea of "not guilty and averred that
he was on his parent’s house at the time of incident.
 However, in a decision under trial court he was convicted of rape with homicide.

Issue:

Whether confession to Municipal Mayor on this case is inadmissible as evidence?

Ruling:

No, It cannot be successfully claimed that the appellant’s confession before the mayor is
inadmissible, it is true that a Mayor has operational supervision and control over the local
police and may arguably be deemed a law enforcement. Appellant’s confession to the
mayor was not made in response to any interrogation. It was the appellant who voluntarily
sought the mayor for a private meeting. Constitutional procedures in custodial investigation
do not apply to spontaneous statement not elicited through questioning by the authorities
but given in an ordinary manner whereby appellant orally admitted having committed the
crime.