People v Endino

Facts: Gerry Galgarin, and his nephew Edward Endino, were accused of murder in the presence of the
victim’s girlfriend. Galgarin was arrested, and was interviewed by TV Patrol where he confessed and
begged his nephew to surrender as well. This confession was admitted by the RTC as evidence for his
guilt. RTC convicted him of the crime of murder. He questioned this before the Supreme Court,
stating that it was forced from him and against his constitutional right. The Court rejected this
contention stating that it did not form part of custodial investigation, since it was given to newsmen
and not the police.

Issue: Whether the ABS-CBN interview recording Galgarin’s confession is

admissible as evidence

Ruling: Yes. The interview was recorded on video and it showed Galgarin unburdening his guilt willingly,
openly and publicly in the presence of newsmen. Such confession does not form part of custodial
investigation as it was not given to police officers but to media men in an attempt to elicit sympathy and
forgiveness from the public.
However, because of the inherent danger in the use of television as a medium for admitting one's guilt,
and the recurrence of this phenomenon in several cases, it is prudent that trial courts are reminded that
extreme caution must be taken in further admitting similar confessions.