22. People v.

Castro eventually transferred to the NarCom Headquarters in San

G.R. No. 106583 June 19, 1997
TOPIC: INSTANCES OF CUSTODIAL
INVESTIGATION
Summary:
This case is an instant appeal assailing the decision of
the Regional Trial Court (RTC) finding the accused Castro
guilty of violating RA 6425. He allege that receipt of property
seized was signed without the assistance of counsel and thus it
is inadmissible as evidence. Although the SC agrees with this
allegation the dearth of evidence against the accused excluding
the said receipt is sufficient enough to convict him beyond
reasonable doubt.
Fernando, La Union where he was asked the said receipt.
Relevant Issue:
Was the receipt legally obtained so as to render it
admissible as evidence?
Ruling: No
Ratio:
The signature in the said receipt was obtained without
the assistance of counsel and is therefore inadmissible as
evidence. Since the said document is a tacit admission of the
crime charged the constitutional safeguards must be observed.
In this case the signature is inadmissible as evidence.

Doctrine:
A receipt of property seized signed without the
assistance of counsel is inadmissible in Court and is presumed
to have been obtained through coercion.
Facts:
This case is an instant appeal assailing the decision of
the Regional Trial Court (RTC) in finding the accused Castro
guilty of violating RA 6425. The NarCom of San Miguel,
Pangasinan acting on an information from a civilian informer
conducted a buy-bust operations. During that operations Sgt.
De Guzman acting as a poseur-buyer allegedly bought from the
accused a kilo of dried marijuana leaves for Php 600.00. After
the transaction was completed Sgt. De Guzman and the other
agents of the NarCom arrested and brought him to the San
Manuel Police Station where he was investigated. He was