Admissibility of Evidence Obtained During Custodial Investigation in the Philippines

Is the affidavit of the person who bought a stolen item from the culprit admissible even if the police officer got his identity from the culprit himself while he was under custodial investigation?

In the Philippines, the admissibility of evidence obtained during a custodial investigation is governed by various legal provisions and jurisprudence aimed at ensuring that the rights of the accused are protected. The focus of this article is on whether the affidavit of a buyer of stolen property is admissible if the police obtained the buyer's identity from the culprit during custodial investigation.

Legal Framework

The Constitution of the Philippines provides clear guidelines regarding custodial investigations. Article III, Section 12 of the 1987 Constitution outlines the rights of individuals under investigation for the commission of an offense. Specifically, it mandates that:

1. Right to Counsel: Any person under investigation has the right to be informed of their right to remain silent and to have competent and independent counsel preferably of their own choice. If the person cannot afford a lawyer, the State must provide one.

2. Miranda Rights: No confession or admission obtained during custodial investigation shall be admissible in evidence unless it is made with the assistance of counsel.

The Nature of Evidence and Its Admissibility

Under the Rules of Court, specifically Rule 128, Section 3, evidence is admissible when it is relevant and not excluded by the Constitution, the law, or the rules. The exclusion of evidence obtained in violation of constitutional rights is a critical safeguard to ensure fair treatment and due process.

Jurisprudence on Evidence from Custodial Investigation

The Supreme Court of the Philippines has consistently upheld the exclusionary rule, which prohibits the admission of evidence obtained in violation of an accused's constitutional rights. In the landmark case of People v. Salazar, the Court held that any information obtained during a custodial investigation without the presence of counsel is inadmissible. This ruling is grounded in the principle that evidence secured in violation of constitutional rights is considered "fruit of the poisonous tree" and, therefore, tainted.

Application to the Query

Given the constitutional protections and the jurisprudence on custodial investigations, the admissibility of the affidavit of a person who bought a stolen item depends on how the police obtained the identity of the buyer. If the police officer learned the identity of the buyer from the culprit during a custodial investigation where the culprit was not informed of their rights, or did not have counsel, this information is likely inadmissible.

However, if the buyer's identity was obtained through an independent source or if the buyer voluntarily provided the affidavit without any coercion or violation of the culprit's rights, the affidavit could be admissible.

Conclusion

In conclusion, the admissibility of an affidavit from a person who purchased a stolen item hinges on the manner in which the information was obtained. If the identity of the buyer was disclosed by the culprit during a custodial investigation without the presence of counsel or without proper advisement of rights, such information is inadmissible in court. The Philippine legal system upholds stringent protections to ensure that any evidence presented in court respects the constitutional rights of all individuals involved.