PEOPLE v OCHAVIDO Justice Abad Santos May 30, 1986 Automatic Review RATIO: The accuseds extrajudicial confession

is admissible in evidence, even though they have not been informed of their Miranda rights prior to their execution, when they have admitted in open court that they have killed the victim. QUICK FACTS: Ochavido and de Ocampo executed an extrajudicial confession admitting the killing of Caponpon. They alleged that they have not been sufficiently warned of their Miranda rights. However, they have also admitted in open court their act of killing the victim. FACTS Accused: Crispino Ochavido and Roman de Ocampo Victim: Gavino Caponpon, their fellow convict in New Bilibid Prison Crime charged: Murder Ochavido and de Ocampo are confined and serving their sentence in the New Bilibid Prison. They were accused of having committed murder against Gavino Caponpon, also a convict. On April 16, 1978, they wrote a letter to then Minister of Jstice Vicente Abad Santos stating that they killed Caponpon for money. They said that Orio and Mario Gallardo hired them to kill Caponpon for P25,000.00. Subsequently, on September 12, 1978, Ochavido and De Ocampo executed extrajudicial confessions. On trial, they claimed that these extrajudicial confessions should not have been admitted in evidence because they were not informed of their Miranda rights prior to their execution. The Solicitor General does not rebut this. Instead, he contends that these extrajudicial statements are not material in determining their guilt, since they admitted in open court that they killed Gavino Caponpon.

ISSUE: WON the extrajudicial statements executed by the Ochavido and De Ocampo are admissible in evidence. YES. Ochavido and De Ocampo sentenced to reclusion perpetua

HELD The Court held that there was substantial compliance with the Miranda provision of the fundamental law then in force. At any rate, Ochavido and De Ocampo have stated in open court that they killed Gavino Caponpon.

In the resolution of this case, the extrajudicial statements have not been accorded probative value because they admitted in open court that they killed the deceased.