People v Ayson 175 SCRA 216 (1989)

Facts: Felipe Ramos was a ticket freight clerk of the Philippine Airlines and was allegedly
involved in irregularities in the sales of plane tickets. The PAL management notified him of
an investigation to be conducted. That investigation was scheduled in accordance with
PAL's Code of Conduct and Discipline, and the Collective Bargaining Agreement signed by it
with the Philippine Airlines Employees' Association (PALEA) to which Ramos pertained. A
letter was sent by Ramos stating his willingness to settle the amount of P76,000. The
findings of the Audit team were given to him, and he refuted that he misused proceeds of
tickets also stating that he was prevented from settling said amounts. He proffered a
compromise however this did not ensue. Two months after a crime of estafa was charged
against Ramos. Ramos pleaded not guilty. Evidence by the prosecution contained Ramos’
written admission and statement, to which defendants argued that the confession was taken
without the accused being represented by a lawyer. Respondent Judge did not admit those
stating that accused was not reminded of his constitutional rights to remain silent and to
have counsel. A motion for reconsideration filed by the prosecutors was denied. Hence this
appeal.

Issue: Whether or Not the respondent Judge is correct in making inadmissible as evidence
the admission and statement of accused.

Held: No. The judge should admit the evidence in court as the accused was not under
custodial investigation when his statements were taken. One cannot invoke violation of the
right to counsel in administrative proceeding. The right to self-incrimination and custodial
investigation are accorded only when the accused is subjected to custodial inquest which
involves the questioning initiated by police authorities after a person is taken in custody or
deprived of his freedom in any way. Because the statements were obtained beyond the
purview of custodial investigation the evidence should be admitted in court.
Rights in custodial interrogation as laid down in miranda v. Arizona: the rights of the
accused include:
1) he shall have the right to remain silent and to counsel, and to be informed of such right.
2) nor force, violence, threat, intimidation, or any other means which vitiates the free will
shall be used against him.
3) any confession obtained in violation of these rights shall be inadmissible in evidence.

He must be warned prior to any questioning that he has the right to remain silent, that
anything he says can be used against him in a court of law, that he has the right to the
presence of an attorney, and that if he cannot afford an attorney one will be appointed for
him prior to any questioning if he so desires. Opportunity to exercise those rights must be
afforded to him throughout the interrogation. After such warnings have been given, such
opportunity afforded him, the individual may knowingly and intelligently waive these rights
and agree to answer or make a statement. But unless and until such warnings and waivers
are demonstrated by the prosecution at the trial, no evidence obtained as a result of
interrogation can be used against him.The objective is to prohibit "incommunicado
interrogation of individuals in a police-dominated atmosphere, resulting in self-incriminating
statement without full warnings of constitutional rights."