Eddie Dean Griffin vs.

State of California

Facts of the case: Eddie Dean Griffin was convicted of 1st degree murder in the Superior Court of Los angeles County, California. He failed to testify on his behalf to deny or comment on the allegations before him by the prosecuting attorney. The responding trial court adversely commented on the silence of the accused and ordered the jury to order the issue of guilt or an inference of guilt upon him due to his failure to testify. The petitioner, herein, only commented on the death penalty imposed by the California court.

Issue: Whether or not the petitioner compelled to testify in a criminal case against him and whether or not the respondent court erred in declaring the petitioner guilty on the ground of his failure to testify.

Held(Supreme Court): The inference of guilt for failure to testify with the accused knowledge of the facts against him is in any event natural and irresistible for any court to say but such comment does not magnify the inference into a penalty for asserting a constitutional privilege. The failure of the accused to explain or deny the allegations of which he had knowledge does not create a presumption of guilt nor by itself warrant an inference of guilt nor relieve the prosecution of nay of its burden of proof. According to the California constitution establishing the defendant¶s privilege against self-incrimination: ³In any criminal case, whether the defendant testifies or not, his failure to explain or to deny by his testimony any evidence or facts in the case against him may be commented upon by the court and by counsel, and may be considered by the court or the jury.´ The Supreme Court bars the adverse comment by the responding court which compelled the accused to testify against himself as it is his constitutional privilege against selfincrimination but concurred on the resolution with regards to the penalty imposed based on the facts of the case not on the failure to testify of the accused. Philippine Law: In the case at bar where it involves the disposition of a resolution by the responding court on the ground that the inference of guilt is established from the failure of the accused to testify violates Sec 17 of the Philippine Constitution which states that no person shall be compelled to be a witness against himself and in relation to Sec 1 which states that no person shall be deprived of life, liberty, or property without due process of law, nor shall any person be denied the equal protection of the laws. It is a constitutional grant or privilege that the accused may waive his or her right to testify on

Filipinized Ruling: Yes. Rights may be waived. In People v. This is clearly a violation of the duty of the court to render justice to every person with due process of the law. Sec. Even in arrest and custodial investigations. the court reiterated the correct procedure for peace officers to follow when conducting arrest and custodial investigation. Any statement of confession or admission obtained in violation the procedure shall be inadmissible in evidence against him. the accused shall be presumed innocent until the contrary is proven. The decision in a criminal proceeding shall solely be based on the strength of evidences presented by the prosecution and not on the weakness or failure on the part of the accused to testify. Pinlac. 14 of 1987 Constitution states that³no person shall be held to answer for a criminal offense without due process of law. unless the waiver is contrary to law.´ The court cannot infer his guilt through his failure to testify. Second paragraph of said section provides that in all criminal prosecution. the accused must be informed of his constitutional rights. the right to counsel and that any statements that he shall make may be used against him. Article III. Also in relation to Art 6 of the Civil Code. or prejudicial to a third person with a right recognized by law. public order. The responding court clearly erred in creating adverse comments by issuing an order of guilt of the accused relying on the silence of latter. public policy.his behalf to deny or explain the allegations before him or her but that does not constitute an inference of guilt for the law clearly mandates that anyone is presumed innocent until proven guilty beyond reasonable doubt in a criminal case. morals or good customs. which states. he cannot waived such right to be heard in court if it falls under the circumstances mentioned in this article but the decision of the court shall not be inferred from the failure of the accused. The prosecution must uphold the strength of its evidence and prove the guilt of the accused beyond reasonable doubt and not rely on the weakness of the defense. It is the peace officer¶s duty to inform the accused of such rights like the right of the accused to remain silent. . warrants the accused to testify on his behalf thereby.

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