G.R. Nos. 71208-09. August 30, 1985 (Case Brief / Digest)

Title: Saturnina Galman and Reynaldo Galman vs. The Honorable Presiding Justice Manuel Pamaran, et al. (The Aquino-Galman Double Murder Case)

On August 21, 1983, former Senator Benigno S. Aquino Jr. was assassinated upon his return to the Philippines at the Manila International Airport (MIA), now Ninoy Aquino International Airport (NAIA), in a crime that shocked the nation and the world. The government, under then-President Ferdinand Marcos, established a fact-finding board chaired by Justice Corazon Juliano-Agrava, later known as the Agrava Board, to investigate the assassination and related events. This Board conducted public hearings, and various individuals, including military personnel and other respondents in this case, were summoned to testify or invited to provide evidence.

Two reports were submitted by the Agrava Board – one by its chairwoman, Justice Agrava, and another by four other members. The reports were turned over to the Tanodbayan (Ombudsman), which then filed two Informations for Murder in the Sandiganbayan, charging several individuals as principals, accomplices, and accessories in the killing of Aquino and Rolando Galman, the latter allegedly presented as Aquino’s assassin but also found dead.

Upon arraignment, all accused, including the private respondents who were high-ranking military officers and enlisted personnel, pleaded not guilty. During the trial, their testimonies before the Agrava Board were offered as evidence against them by the prosecution, which the accused objected to on the grounds of self-incrimination and the immunity provision in P.D. 1886 that created the Agrava Board. The Sandiganbayan issued a resolution admitting the prosecution’s evidence except for the testimonies and other evidence produced by the accused before the Agrava Board in view of the immunity granted by P.D. 1886. This resolution was challenged before the Supreme Court.

1. Whether the testimonies given and evidence produced by private respondents before the Agrava Board, without invoking their right against self-incrimination, are admissible in evidence against them in the criminal cases for the assassination of Benigno Aquino Jr. and Rolando Galman.
2. The interpretation of the immunity provision in P.D. 1886, particularly whether the immunity from the use of said testimonies and evidence applies despite the failure of the private respondents to claim their privilege against self-incrimination before the Agrava Board.

Court’s Decision:
The Supreme Court, in dismissing the petition, held that the testimonies and evidence given by the private respondents before the Agrava Board are inadmissible in the criminal cases before the Sandiganbayan. It reasoned that the compelled testimonies and production of evidence were given under the presumption of immunity as provided by P.D. 1886. Because the private respondents were compelled to testify or produce evidence, their failure to invoke the privilege against self-incrimination before the Agrava Board does not deprive them of the immunity from the use of such testimonies and evidence against them in subsequent prosecutions. The Court found that P.D. 1886 compelled witnesses to testify under threat of contempt, thereby overriding their constitutional rights to remain silent and against self-incrimination, which must be protected by construing the decree to afford them immunity without needing to claim it explicitly before the Agrava Board.

The doctrine established in this case is that testimony or evidence compelled from individuals under legal provisions that override their constitutional rights to silence and against self-incrimination cannot be used against them in any subsequent prosecution, regardless of whether they invoked such rights during the compelled testimony or evidence production. This is premised on the protection afforded by the immunity provision in the decree compelling the testimony or evidence, which must be construed to preserve the individuals’ constitutional protections.

Class Notes:
The key concepts central to this case include the constitutional rights against self-incrimination and to remain silent, immunity provisions in legislation, and the conditions under which compelled testimonies and evidences are admissible in court. The case underscores the importance of construing statutes in a manner that upholds constitutional rights and the principle that immunity from the use of compelled testimonies or evidences applies automatically in the face of statutory compulsion to testify, without the necessity of invoking such rights at the time of compulsion.

Historical Background:
The assassination of Benigno Aquino Jr., a prominent opposition leader, upon his return from exile marked a critical point in Philippine history, leading to heightened political unrest and contributing to the eventual fall of the Marcos regime. The establishment of the Agrava Board and the subsequent legal battles concerning the admissibility of testimonies highlighted the complexities of seeking justice for Aquino’s assassination against a backdrop of martial law and entrenched political power, emphasizing the tension between state mechanisms of investigation and constitutional rights.


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