18. People v.

Bolanos The court then basing its verdict on this admission and finds
him guilty of murder.
G.R. No. 101808 July 3, 1992
Relevant Issue:
TOPIC: INSTANCES OF CUSTODIAL
INVESTIGATION Was the admission made in the vehicle on the way to
the police station inadmissible as evidence?
Summary:
Ruling: Yes
This case is a review of the decision of the Regional
Trial Court (RTC) finding the accused Bolanos guilty of Ratio:
Murder. The OSG in its manifestation said that the admission
made by Bolanos on their way to the police station, which was Since the accused was already under custodial
the basis for his conviction, is inadmissible as evidence since it investigation on the way to the police station he should already
violated the accused’s constitutional rights. The SC agrees with have been informed of his rights and should have already been
the position of the OSG and acquits Bolanos. assisted by counsel. Such admission is against the interest of
the accused and it should have been done under the within the
Doctrine: bounds provided by the protection of the Constitution. Since in
this case the same is not done within that prescribed protection
An admission without assistance of counsel made in the the admission is rendered inadmissible as evidence therefore
vehicle under police custody on the way to the police station the accused must be acquitted.
for the investigation is inadmissible as evidence. For in such a
situation the accused must have already been informed of his
rights and that it is already considered as a part of custodial
investigation.
Facts:
Bolanos was one of the last two companions of the
deceased Pagdalian who was found dead in a makeshift bed
with stab wounds. During the investigation of the police in the
crime scene as they were talking to the accused they found in
his seat the weapon which was used as in the murder of the
deceased. Thereafter Bolanos and his other companion was
invited by the police for investigation. In the vehicle on the
way to the police station Bolanos admitted to killing the victim.