The police served a warrant of arrest on Ariston who was suspected of raping and killing a female high school student. While on the way to the police station, one of the police officers who served the warrant asked Ariston in the local dialect if he really raped and killed the student, and Ariston nodded and said, “Opo.” Upon arriving at the police station, Ariston saw the City Mayor, whom he approached and asked if they could talk privately. The Mayor led Ariston to his office and, while there in conversation with the Mayor, Ariston broke down and admitted that he raped and killed the student. The Mayor thereafter opened the door of the room to let the public and media representatives witness Ariston’s confession. In the presence of the Mayor, the police and the media, and in response to questions asked by some members of the media, Ariston sorrowfully confessed his guilt and sought forgiveness for his actions.
Which of these extrajudicial confessions, if any, would you consider as admissible in evidence against Ariston? (5%)
Suggested answer only. Not an official answer and not legal advice.
Only Ariston's confessions to the Mayor and the media are admissible, while his confession to the police is inadmissible. Under Article III, Section 12 of the Constitution, uncounseled admissions elicited during custodial investigation are inadmissible.
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Quick check
When does custodial investigation begin for the purpose of applying Miranda rights under Article III, Section 12 of the Constitution?
Custodial investigation begins when police inquiry focuses on a specific suspect in custody.
Why is Ariston's extrajudicial confession to the police officer while en route to the station inadmissible in evidence?
Confessions elicited during custodial interrogation without Miranda warnings and counsel are inadmissible.
Is a voluntary extrajudicial confession made privately to a City Mayor admissible against an accused?
Confessions made to a mayor acting as a confidant outside custodial investigation are admissible.
Under the ruling in People v. Andan, what is the legal status of an extrajudicial confession made to news reporters?
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Which constitutional provision excludes extrajudicial confessions obtained in violation of custodial investigation rights?
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Learn more about these topics
1. Custodial Investigation Rights
Under Article III, Section 12 of the 1987 Constitution, any person under custodial investigation for the commission of an offense shall have the right to be informed of his right to remain silent and to have competent and independent counsel. Custodial investigation begins when the investigation ceases to be a general inquiry into an unsolved crime and starts to focus on a particular suspect who has been taken into police custody. Any extrajudicial confession or admission obtained from an accused during custodial interrogation without the assistance of counsel or valid waiver is unconstitutional and inadmissible in evidence.
2. Confessions To Mayor
Under established jurisprudence, extrajudicial confessions made by an accused to a municipal mayor acting as a personal confidant rather than a law enforcement officer do not fall under custodial investigation. When an accused voluntarily approaches a mayor privately to confess without police coercion, intimidation, or interrogation, the mayor acts in a non-investigative capacity. Consequently, constitutional Miranda warnings and the presence of legal counsel are not required for admissibility, rendering an uncounseled voluntary confession made spontaneously to a mayor admissible in evidence against the accused.
3. Media Extrajudicial Confessions
Extrajudicial confessions made spontaneously by an accused to news reporters or media representatives are admissible in evidence. In People v. Andan, the Supreme Court held that media interviews conducted voluntarily without police coercion or interrogation fall outside the scope of custodial investigation. When an accused freely answers questions posed by journalists without being compelled by police officers, the constitutional safeguards under Article III, Section 12 do not apply. Statements made voluntarily to reporters constitute verbal admissions against interest, which are fully admissible against the accused in criminal proceedings.