Filoteo v Sandiganbayan

SCRA 222 (1996)G.R. No. 79543 Filoteo, Jr. v. Sandiganbayan263 Facts: Petitioner Jose D. Filoteo, Jr. was a police investigator of the Western Police District inMetro Manila, an old hand at dealing with suspected criminals. A recipient of variousawards and commendations attesting to his competence and performance as a policeofficer, he could not therefore imagine that one day he would be sitting on the other sideof the investigation table as the suspected mastermind of the armed hijacking of apostal delivery van.Filoteo admitted involvement in the crime and pointed to three other soldiers, namely,E d d i e S a g u i n d e l , B e r n a r d o Re l a t o r a n d J a c k M i r a v a l l e s ( w h o t u r n e d o u t t o b e a discharged soldier), as his confederates. At 1:45 in the afternoon of May 30, 1982,petitioner executed a sworn statement in Tagalog before M/Sgt. Arsenio C. Carlos andSgt. Romeo P. Espero.Peitioner however sought later that his confession be inadmissible evidence, saying thatthe law should favour him as an accused. Issue: Whether or not Article III, Section 12 of the 1987 Constituti o n s h a l l b e g i v e n a retroactive eff ect and petitioner’s extrajudicial con fession be held as inadmissibleevidence Held: No, since what he did was not a penal offense. Under the penal law, a person guilty of felony who is not a habitual criminal may be given favour by the law

JOSE D. FILOTEO, JR., petitioner, vs. SANDIGANBAYAN and THE PEOPLE OF THE PHILIPPINES, respondents.

Facts:

Petitioner Jose D. Filoteo, Jr. was a police investigator of the Western Police District in Metro Manila, an old hand at dealing with suspected criminals. A recipient of various awards and commendations attesting to his competence and performance as a police officer, he could not therefore imagine that one day he would be sitting on the other side of the investigation table as the suspected mastermind of the armed hijacking of a postal delivery van. Filoteo admitted involvement in the crime and pointed to three other soldiers, namely ,Eddie Saguindel, Bernardo Relator and Jack Miravalles (who turned out to be adischarged soldier), as his confederates. At 1:45 in the afternoon of May 30, 1982,petitioner executed a sworn statement in Tagalog before M/Sgt. Arsenio C. Carlos and Sgt. Romeo P. Espero. Peitioner however sought later that his confession be inadmissible evidence, saying that the law should favour him as an accused.

Issue: Whether or not Article III, Section 12 of the 1987 Constitution shall be given a retroactive effect and petitioner’s extrajudicial confession be held as inadmissible evidence.

RULING: No, since what he did was not a penal offense. Under the penal law, a person guilty of felony who is not a habitual criminal may be given favour by the law.