Facts and Case Summary - Miranda v.

Arizona

Facts

The Supreme Court’s decision in Miranda v. Arizona addressed four different cases involving custodial
interrogations. In each of these cases, the defendant was questioned by police officers, detectives, or a
prosecuting attorney in a room in which he was cut off from the outside world. In none of these cases
was the defendant given a full and effective warning of his rights at the outset of the interrogation
process. In all the cases, the questioning elicited oral admissions and, in three of them, signed
statements that were admitted at trial.

 Miranda v. Arizona: Miranda was arrested at his home and taken in custody to a police station
where he was identified by the complaining witness. He was then interrogated by two police
officers for two hours, which resulted in a signed, written confession. At trial, the oral and
written confessions were presented to the jury. Miranda was found guilty of kidnapping and
rape and was sentenced to 20-30 years imprisonment on each count. On appeal, the Supreme
Court of Arizona held that Miranda’s constitutional rights were not violated in obtaining the
confession.

 Vignera v. New York: Vignera was picked up by New York police in connection with the robbery
of a dress shop that had occurred three days prior. He was first taken to the 17th Detective
Squad headquarters. He was then taken to the 66th Detective Squad, where he orally admitted
the robbery and was placed under formal arrest. He was then taken to the 70th Precinct for
detention, where he was questioned by an assistant district attorney in the presence of a
hearing reporter who transcribed the questions and answers. At trial, the oral confession and
the transcript were presented to the jury. Vignera was found guilty of first degree robbery and
sentenced to 30-60 years imprisonment. The conviction was affirmed without opinion by the
Appellate Division and the Court of Appeals.

 Westover v. United States: Westover was arrested by local police in Kansas City as a suspect in
two Kansas City robberies and taken to a local police station. A report was also received from
the FBI that Westover was wanted on a felony charge in California. Westover was interrogated
the night of the arrest and the next morning by local police. Then, FBI agents continued the
interrogation at the station. After two-and-a-half hours of interrogation by the FBI, Westover
signed separate confessions, which had been prepared by one of the agents during the
interrogation, to each of the two robberies in California. These statements were introduced at
trial. Westover was convicted of the California robberies and sentenced to 15 years’
imprisonment on each count. The conviction was affirmed by the Court of Appeals for the Ninth
Circuit.

 California v. Stewart: In the course of investigating a series of purse-snatch robberies in which

one of the victims died of injuries inflicted by her assailant, Stewart was identified as the
endorser of checks stolen in one of the robberies. Steward was arrested at his home. Police also
arrested Stewart’s wife and three other people who were visiting him. Stewart was placed in a
cell, and, over the next five days, was interrogated on nine different occasions. During the ninth
interrogation session, Stewart stated that he had robbed the deceased, but had not meant to
hurt her. At that time, police released the four other people arrested with Stewart because
 there was no evidence to connect any of them with the crime. At trial, Stewart’s statements
were introduced. Stewart was convicted of robbery and first-degree murder and sentenced to
death. The Supreme Court of California reversed, holding that Stewart should have been advised
of his right to remain silent and his right to counsel.

Issues

Whether “statements obtained from an individual who is subjected to custodial police interrogation”
are admissible against him in a criminal trial and whether “procedures which assure that the individual is
accorded his privilege under the Fifth Amendment to the Constitution not to be compelled to
incriminate himself” are necessary.

Supreme Court holding

The Court held that “there can be no doubt that the Fifth Amendment privilege is available outside of
criminal court proceedings and serves to protect persons in all settings in which their freedom of action
is curtailed in any significant way from being compelled to incriminate themselves.” As such, “the
prosecution may not use statements, whether exculpatory or inculpatory, stemming from custodial
interrogation of the defendant unless it demonstrates the use of procedural safeguards effective to
secure the privilege against self-incrimination. By custodial interrogation, we mean questioning initiated
by law enforcement officers after a person has been taken into custody or otherwise deprived of his
freedom of action in any significant way.”

The Court further held that “without proper safeguards the process of in-custody interrogation of
persons suspected or accused of crime contains inherently compelling pressures which work to
undermine the individual’s will to resist and to compel him to speak where he would otherwise do so
freely.” Therefore, a defendant “must be warned prior to any questioning that he has the right to
remain silent, that anything he says can be used against him in a court of law, that he has the right to
the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior
to any questioning if he so desires.”

The Supreme Court reversed the judgment of the Supreme Court of Arizona in Miranda, reversed the
judgment of the New York Court of Appeals in Vignera, reversed the judgment of the Court of Appeals
for the Ninth Circuit in Westover, and affirmed the judgment of the Supreme Court of California
in Stewart.
HO WAI PANG v. PEOPLE OF THE PHILIPPINES. G.R. No. 176229. October 19, 2011.

FACTS:

When Gilda Cinco search the bag of Ho Wai Pang in the Baggage Declaration at the arrival area, she
found boxes of chocolate which when she saw inside had white substance. They were then brought to
the PNP after the procedures in the airport.

The RTC found Pang guilty of violation of the Dangerous Drugs Act. The CA while affirming the RTC
decision took note that their right to counsel during custodial investigation was violated.

ISSUE: Whether the violation of the petitioner's right to counsel made the evidence taken from the
petitioner inadmissible.

RULING:

The SC held in the negative. The SC reiterated that infractions to the accused during the custodial
investigation render only extrajudicial confession or admissions of the suspect inadmissible as evidence.

Also, the guilt of Pang was based on the testimony of Cinco when she caught Pang in flagrante delicto
transporting shabu.
Luz v. People of the Philippines, G.R. No. 197788, 29 February 2012.

18APR

[SERENO, J.]

FACTS: PO3 Alteza flagged down Rodel Luz for violating a municipal ordinance which requires all
motorcycle drivers to wear helmets while driving their motorcyles. PO3 Alteza invited the Luz to come
inside their sub-station since the place where he flagged down the Luz is almost in front of the said sub-
station. While issuing a citation ticket for violation of municipal ordinance, PO3 Alteza noticed that Luz
was uneasy and kept on getting something from his jacket. Alerted and so, he told the Luz to take out
the contents of the pocket of his jacket as the latter may have a weapon inside it. Luzo bliged and
slowly put out the contents of the pocket of his jacket which was a nickel-like tin or metal container
about two (2) to three (3) inches in size, including two (2) cellphones, one (1) pair of scissors and one (1)
Swiss knife. Upon seeing the said container, he asked Luz to open it. After Luz opened the container,
PO3 Alteza noticed a cartoon cover and something beneath it, and that upon his instruction, the former
spilled out the contents of the container on the table which turned out to be four (4) plastic sachets, the
two (2) of which were empty while the other two (2) contained suspected shabu. Luz was later charged
for illegal possession of dangerous drugs. Luz claims that there was no lawful search and seizure because
there was no lawful arrest. The RTC found that Luz was lawfully arrested. Upon review, the CA affirmed
the RTCs Decision.

ISSUE #1: Can Luz be considered lawfully arrested based on traffic violation under the city ordinance,
and such arrest lead to a valid search and seizure?

HELD #1: NO, Luz was not lawfully arrested. When he was flagged down for committing a traffic
violation, he was not, ipso facto and solely for this reason, arrested.

Arrest is the taking of a person into custody in order that he or she may be bound to answer for the
commission of an offense. It is effected by an actual restraint of the person to be arrested or by that
persons voluntary submission to the custody of the one making the arrest. Neither the application of
actual force, manual touching of the body, or physical restraint, nor a formal declaration of arrest, is
required. It is enough that there be an intention on the part of one of the parties to arrest the other, and
that there be an intent on the part of the other to submit, under the belief and impression that
submission is necessary.

At the time that he was waiting for PO3 Alteza to write his citation ticket, petitioner could not be said to
have been under arrest. There was no intention on the part of PO3 Alteza to arrest him, deprive him of
his liberty, or take him into custody. Prior to the issuance of the ticket, the period during which
petitioner was at the police station may be characterized merely as waiting time. In fact, as found by the
trial court, PO3 Alteza himself testified that the only reason they went to the police sub-station was that
petitioner had been flagged down almost in front of that place. Hence, it was only for the sake of
convenience that they were waiting there. There was no intention to take petitioner into custody.

This ruling does not imply that there can be no arrest for a traffic violation. Certainly, when there is an
intent on the part of the police officer to deprive the motorist of liberty, or to take the latter into
custody, the former may be deemed to have arrested the motorist. In this case, however, the officers
issuance (or intent to issue) a traffic citation ticket negates the possibility of an arrest for the same
violation.

ISSUE #2: Assuming that Luz was deemed arrested, was there a valid warrantless search and seizure that
can still produce conviction?

HELD#2: NO. Even if one were to work under the assumption that Luz was deemed arrested upon being
flagged down for a traffic violation and while awaiting the issuance of his ticket, then the requirements
for a valid arrest were not complied with.

This Court has held that at the time a person is arrested, it shall be the duty of the arresting officer to
inform the latter of the reason for the arrest and must show that person the warrant of arrest, if any.
Persons shall be informed of their constitutional rights to remain silent and to counsel, and that any
statement they might make could be used against them. It may also be noted that in this case, these
constitutional requirements were complied with by the police officers only after petitioner had been
arrested for illegal possession of dangerous drugs.

[T]here being no valid arrest, the warrantless search that resulted from it was likewise illegal. The
subject items seized during the illegal arrest are inadmissible. The drugs are the very corpus delicti of the
crime of illegal possession of dangerous drugs. Thus, their inadmissibility precludes conviction and calls
for the acquittal of the accused.
Case Digest: PHILCOMSAT v. Senate

G.R. No. 180308 : June 19, 2012

PHILCOMSAT HOLDINGS CORPORATION, ENRIQUE L. LOCSIN AND MANUEL D. ANDAL, Petitioners, v.

SENATE OF THE REPUBLIC OF THE PHILIPPINES, SENATE COMMITTEE ON GOVERNMENT
CORPORATIONS AND PUBLIC ENTERPRISES, SENATE COMMITTEE ON PUBLIC SERVICES, HON. SEN.
RICHARD GORDON AND HON. SEN. JUAN PONCE ENRILE,Respondents.

PERLAS-BERNABE, J.:

FACTS:

PHILCOMSAT is a wholly-owned subsidiary of the Philippine Overseas Telecommunications Corporation

(POTC), a government-sequestered organization in which the Republic of the Philippines holds a 35%
interest in shares of stocks. For the period from 1986 to 1996, the government, through the Presidential
Commission on Good Government (PCGG), regularly received cash dividends from POTC. However,
POTC suffered its first loss.

In view of the losses that the government continued to incur and in order to protect its interests in
POTC, PHILCOMSAT and PHC, Senator Miriam Defensor Santiago, during the Second Regular Session of
the Thirteenth Congress of the Philippines, introduced Proposed Senate Resolution (PSR) No. 455
directing the conduct of an inquiry, in aid of legislation, on the anomalous losses incurred by POTC,
PHILCOMSAT and PHC and the mismanagement committed by their respective board of directors.

Respondents Senate Committees submitted the assailed Committee Report No. 312, where it noted the
need to examine the role of the PCGG in the management of POTC, PHILCOMSAT and PHC. After due
proceedings, the respondents Senate Committees found overwhelming mismanagement by the PCGG
and its nominees over POTC, PHILCOMSAT and PHC, and that PCGG was negligent in performing its
mandate to preserve the government's interests in the said corporations. In sum, Committee Report No.
312 recommended, inter alia, the privatization and transfer of the jurisdiction over the shares of the
government in POTC and PHILCOMSAT to the Privatization Management Office (PMO) under the
Department of Finance (DOF) and the replacement of government nominees as directors of POTC and
PHILCOMSAT.

Petitioners filed the instant petition before the Court, questioning, in particular, the haste with which
the respondent Senate approved the challenged Committee Report No. 312.

ISSUE: Whether or not Committee Resolution No. 312 should be nullified, having proposed no piece of
legislation and having been hastily approved by the respondent Senate?

HELD: Committee Report No. 312 is sustained.

CONSTITUTIONAL LAW: senate's power of inquiry

The respondents Senate Committees' power of inquiry relative to PSR No. 455 has been passed upon
and upheld in the consolidated cases of In the Matter of the Petition for Habeas Corpus of Camilo L.
Sabio, which cited Article VI, Section 21 of the Constitution, as follows:

"The Senate or the House of Representatives or any of its respective committees may conduct inquiries
in aid of legislation in accordance with its duly published rules of procedure. The rights of persons
appearing in or affected by such inquiries shall be respected."

The Court explained that such conferral of the legislative power of inquiry upon any committee of
Congress, in this case the respondents Senate Committees, must carry with it all powers necessary and
proper for its effective discharge.

On this score, the respondents Senate Committees cannot be said to have acted with grave abuse of
discretion amounting to lack or in excess of jurisdiction when it submitted Committee Resolution No.
312, given its constitutional mandate to conduct legislative inquiries. Nor can the respondent Senate be
faulted for doing so on the very same day that the assailed resolution was submitted. The wide latitude
given to Congress with respect to these legislative inquiries has long been settled, otherwise, Article VI,
Section 21 would be rendered pointless.

DISMISSED