1193 Santos v. Sandiganbayan [Salvador, A.]

Case No. 1193

SANTOS v. SANDIGANBAYAN G.R. No. 71523-25 December 8, 2000 FACTS OF THE CASE In the three consolidated cases at bar, the petitioners herein were charged with estafa through falsification of public documents. The Sandiganbayan filed the information against the petitioners-accused alleging that the latter were able to acquire 9 million pesos from their scheme. As found out by the Supreme Court, the accused were able to infiltrate the Clearing Center of the Central Bank of the Philippines through different  bank accounts in different banks. These were termed as the switching and pilferage schemes. These schemes also made use of their positions as employees of such banks in order to accomplish the same.

Subsequently, in an operation of the National Bureau of Investigation, they were taken into custody for investigation and interrogation. According to the prosecution, petitioners-accused knowingly waived their right to counsel and right to remain silent. As evidenced by a document, signed by petitioners, entitled “WAIVER,” the prosecution alleged that the statements made by the petitioners were done with full consent and knowledge of the waiver of their constitutional rights. Further, they alleged that the accused were fully informed of their constitutional right to remain silent and right to counsel. ISSUE/S Whether or not the statements made by the accused are admissible in evidence and that the waiver of right is a valid waiver of said right HELD/RATIO The Supreme Court ruled that, “[t]he “ [t]he statements were intelligently executed is borne out by the fact that  both confessants have reached the tertiary level of education: education: Valentino holds the degree of Bachelor of Science in Commerce while petitioner Estacio reached the first year of college education in banking and finance. Possessed with sufficient education and not proven to be mentally unfit, they could have protested the forced extraction of culpability from themselves if indeed that was true.

Moreover, the extrajudicial confessions in question are replete with details on the manner in which the crimes were committed, thereby ruling out the probability that these were involuntarily made. Voluntariness of a confession may be inferred from its language such that, if upon its face the confession exhibits no sign of suspicious circumstances tending to cast doubt upon its integrity, it  being replete replete with details details which could possibly possibly be supplied supplied only by the the accused accused reflecting spontaneity spontaneity and coherence which, psychologically, cannot be associated with a mind to which violence and torture have  been applied, applied, it may may be considered considered voluntary. voluntary.””

Prepared by: Antonio Dominic G. Salvador