People vs. Endino, GR 133026, 20 February 2001

People vs. Endino, GR 133026, 20 February 2001 

FACTS:

• Gerry Galgarin and his nephew Edward Endino were accused of slaying Dennis Aquino, where the former stabbed him several times and the latter shot him. This was done in the presence of the victim’s girlfriend.
• Galgarin was arrested and interviewed by TV Patrol where he confessed and begged his nephew to surrender as well. 
• This confession was admitted by the trial court as evidence for his guilt. Trial court convicted him of the crime of murder
• He questioned this before the Supreme Court, stating that it was forced from him and against his constitutional right. 
• The Court rejected his contention stating that it was not part of the custodial investigation, since it was given to newsmen and not to police. 
• It however cautioned lower court from admitting evidence such as this, since it should be done only after scrutiny to avoid abuse and legalizing coerced extra-judicial confessions. 

 
ISSUE:
Whether or not trial court erred in admitting the videotape confession as evidence . 
 
RULING:
No.
​The interview and confession does not form part of custodial investigation since it was not given to the police officers but to the media in an attempt to elicit sympathy and forgiveness from the public. However, because of the inherent danger in the use of television as a medium for admitting guilt, it is prudent that trial courts are reminded that extreme caution must be taken in further admitting similar confessions. We should never presume that all media confessions described as voluntary have been given freely. It should be thoroughly examined and scrutinized.