CASE DIGEST: PEOPLE OF THE PHILIPPINES VS. EDWARD ENDINO (at large) AND GERRY GALGARIN ALIAS TOTO. G.R. No. 133026. February 20, 2001

FACTS:

Out of revenge, Edward Endino, with the aid of his uncle Gerry Galgarin, killed Dennis Aquino in the presence of one Clara Agagas whose love they once shared. 

The facts shown that Gerry suddenly stabbed Dennis repeatedly on the chest in Puerto Princesa City. Dennis managed to momentarily free himself from Galgarin and escape, but out of nowhere, Eduard appeared and fired at Dennis. He died along the way going to the hospital. 

Later on, an information for murder was charged against Eduard and Gerry, who at that time are at large and their whereabouts are unknown. 

After one year of escape, Gerry was found and arrested in Antipolo. Before going back to Palawan for his trial, Gerry and the arresting police officers stopped at ABS-CBN Television station. Gerry was interviewed by reporters. He admitted his guilt and pointed to his nephew Eduard as the gunman. He also pleaded to Eduard to surrender to the authorities. Video footages of the interview of Gerry were presented by the prosecution as evidence in his murder case. 

However, Gerry later on disowned that confession and claimed that it was induced by the threats of the arresting police officers. 

ISSUE: 

Whether the video footages of confession made by Gerry is admissible as evidence.

RULING:

Yes. The interview was recorded on video and it showed that Gerry unburdening his guilt willingly, openly and publicly in the presence of newsmen. Such confession does not form part of custodial investigation as it was not given to police officers but to media men in an attempt to elicit sympathy and forgiveness from the public. Besides, if he had indeed been forced into confessing, he could have easily sought succor from the newsmen who, in all likelihood, would have been symphatetic with him. 

However,  because of the inherent danger in the use of television as a medium for admitting one's guilt,  and the recurrence of this phenomenon in several cases, the court gives reminder to the trial courts to be cautious in further admitting similar confessions. There's a probability that the police, in connivace with the media practitioners,  may attempt to legitimized coerced extrajudicial confessions and place them beyond the exclusionary rule by having an accused admit an offense on television.