Case Title: People vs Dano

Summary:
An admission by the accused before the barangay
captain, who is neither a police officer nor a law enforcement
agent, even if done without the assistance of a lawyer, is not in
violation of the accused’s constitutional rights. The
constitutional requirements on custodial investigation do not
apply to spontaneous statements made in a voluntary manner
Facts:
Alberto Dano was found guilty by the trial court for the
crime of murder in killing his brother. When interrogated by the
police, appellant, without assistance of counsel, admitted he
killed his brother.
Issue:
WON the extra judicial confession of Dano is
admissible as evidence.
Held:
NO. A suspect’s confession, whether verbal or non-
verbal, when taken without the assistance of counsel without a
valid waiver of such assistance regardless of the absence of
coercion or the fact that it had been voluntarily given, is
inadmissible as evidence, even if the accused’s confession
were gospel truth. Extrajudicial confessions must conform to
the requirements of the Constitution.