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 petitioners 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 petitioners 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.