This case has been cited 2 times or more.
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2005-11-17 |
YNARES-SANTIAGO, J. |
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| Along the same vein, we held that a videotaped interview showing the accused unburdening his guilt willingly, openly and publicly in the presence of newsmen is not covered by the provision although in so ruling, we warned trial courts to take extreme caution in further admitting similar confessions because we recognized the distinct possibility that the police, with the connivance of unscrupulous media practitioners, may attempt to legitimize coerced extrajudicial confessions and place them beyond the exclusionary rule by having an accused admit an offense on television.[25] | |||||
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2002-02-06 |
YNARES-SANTIAGO, J. |
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| The court a quo did not err in admitting in evidence accused-appellant's taped confession. Such confession did not form part of custodial investigation. It was not given to police officers but to a media man in an apparent attempt to elicit sympathy. The record even discloses that accused-appellant admitted to the Barangay Captain that he clubbed and stabbed the victim even before the police started investigating him at the police station.[19] Besides, if he had indeed been forced into confessing, he could have easily asked help from the newsman. In People v. Endino, et al.,[20] we held:We do not suggest that videotaped confessions given before media men by an accused with the knowledge of and in the presence of police officers are impermissible. Indeed, the line between proper and invalid police techniques and conduct is a difficult one to draw, particularly in cases such as this where it is essential to make sharp judgments in determining whether a confession was given under coercive physical or psychological atmosphere. Even assuming for the nonce that the extra-judicial confession was indeed inadmissible, this will not absolve accused-appellant from criminal liability because there exists independent evidence to establish his authorship of the victim's death. While there was no prosecution witness who positively identified accused-appellant as the assailant of the victim, his culpability was nonetheless proven through circumstantial evidence. | |||||