Primary Holding

This case arises from the assassination of former Senator Benigno S. Aquino Jr. in 1983 at Manila International Airport. The primary issue concerns the admissibility of testimonies and evidence provided by suspects before the Agrava Fact-Finding Board, especially in light of their constitutional right against self-incrimination and the immunity granted under Presidential Decree No. 1886. The Supreme Court upheld the exclusion of the testimonies and evidence submitted to the Agrava Board, reinforcing constitutional protections against self-incrimination.

Background

The assassination of Senator Benigno S. Aquino Jr. on August 21, 1983, led to the creation of the Agrava Fact-Finding Board under P.D. 1886. The Board investigated the incident and gathered testimonies, including those from suspects. Legal questions arose during subsequent trials regarding the admissibility of evidence obtained under mandatory compulsion by the Board.

Facts

• 1. Senator Aquino was assassinated upon returning to the Philippines.
• 2. Several members of the military were implicated and summoned to testify before the Agrava Board.
• 3. The military respondents claimed immunity under P.D. 1886 but did not invoke their right against self-incrimination during testimony.
• 4. The prosecution attempted to use these testimonies in criminal cases before the Sandiganbayan.

Arguments of the Petitioners

• 1. The respondents waived their right against self-incrimination by failing to invoke it during the Agrava Board proceedings.
• 2. The immunity granted under P.D. 1886 does not automatically apply without an explicit invocation of the privilege.
• 3. Excluding the testimonies undermines the pursuit of justice.

Arguments of the Respondents

• 1. The testimonies were compelled, making their admission unconstitutional under the right against self-incrimination.
• 2. Immunity under P.D. 1886 must cover all compelled testimony, regardless of invocation.
• 3. Admitting the evidence would violate both procedural due process and constitutional rights.

Issues

• 1. Was the respondents’ right against self-incrimination violated by using their compelled testimony?
• 2. Is explicit invocation of the privilege against self-incrimination necessary to claim immunity under P.D. 1886?

Ruling

• 1. The Court ruled in favor of the respondents, affirming the Sandiganbayan's exclusion of the testimonies.
• 2. The compelled testimonies violated the constitutional right against self-incrimination.
• 3. Immunity under P.D. 1886 must be construed liberally to ensure due process.
• 4. Invocation of the right against self-incrimination is unnecessary when compulsion is clear.

Doctrines

• 1. Right Against Self-Incrimination (Art. IV, Sec. 20, 1973 Constitution): Protection extends beyond custodial investigation and prohibits compelled testimony in any government proceeding unless immunity is granted.
• 2. Immunity Doctrine: Compelled testimony is inadmissible unless transactional or use immunity is explicitly and sufficiently provided.

Precedents Cited

• 1. Chavez v. Court of Appeals: Established the breadth of the self-incrimination clause.
• 2. Cabal v. Kapunan: Affirmed that the right applies outside of criminal cases.

Statutory and Constitutional Provisions

• 1. Section 20, Article IV, 1973 Constitution (Right Against Self-Incrimination)
• 2. P.D. 1886, Section 5 (Compelled Testimony with Immunity)