### Facts:
On September 6, 1991, United Arab Emirates Airlines Flight No. 068 from Hong Kong arrived at the Ninoy Aquino International Airport (NAIA) with 13 Hong Kong nationals, including petitioner Ho Wai Pang, arriving as tourists. During a routine inspection by Customs Examiner Gilda L. Cinco, suspicious items were found in their baggage, leading to the discovery of 18 chocolate boxes containing methamphetamine hydrochloride or shabu from six out of the 13 tourists, including the petitioner. Following tests and investigation by NARCOM and the NBI, only six were charged with violation of Section 15, Article III of Republic Act (R.A.) No. 6425, otherwise known as the Dangerous Drugs Act of 1972. The Regional Trial Court (RTC), after a series of pleadings including a Motion for Reinvestigation by Ho Wai Pang, found the accused guilty, a decision that was later affirmed by the Court of Appeals (CA) upon appeal.
### Issues:
1. Whether the petitioner’s right during custodial investigation was breached, and if so, impact on evidence admissibility.
2. Whether the petitioner was deprived of the right to confront witnesses against him.
3. The existence of conspiracy among the accused.
4. Whether the prosecution proved the guilt of the petitioner beyond reasonable doubt.
### Court’s Decision:
The Supreme Court denied the petition and affirmed the decisions of both the RTC and CA, holding that:
1. The violation of Miranda Rights only affects the admissibility of extrajudicial confessions, not other types of evidence. Since no inculpatory statement from the custodial investigation was used against Ho Wai Pang, this point did not merit consideration.
2. The right to confrontation was not violated as the petitioner, through counsel, had the opportunity to cross-examine witnesses.
3. Conspiracy among the accused was established through circumstantial evidence indicating a common design and concerted action among them.
4. The petitioner’s guilt for transporting methamphetamine hydrochloride was proven beyond a reasonable doubt based on the credible testimony of the prosecution witnesses and the evidence of the shabu found.
### Doctrine:
The Supreme Court reiterated the principle that violations of Miranda Rights render inadmissible only the extrajudicial confessions or admissions made during custodial investigation. The admissibility of other evidence remains unaffected if they are relevant to the issue and not otherwise excluded by law or rules.
### Class Notes:
– **Miranda Rights Violation**: Affects only the admissibility of extrajudicial confessions or admissions.
– **Right to Confrontation**: Ensures the accused can cross-examine witnesses. The full exercise of this right is not impeded as long as the accused, through counsel, has an opportunity for cross-examination.
– **Conspiracy**: Can be proven through direct or circumstantial evidence showing a common plan or action among accused.
– **Proof Beyond Reasonable Doubt**: Requires that the guilt of the accused must be proven such that there leaves no room for reasonable doubt based on the evidence presented.
### Historical Background:
This case underscores the Philippine legal system’s assertion on the proper observance of constitutional rights during custodial investigations and trials. It further clarifies the extent to which violations of these rights impact the admissibility of evidence and the appraisal of guilt, particularly in drug-related offenses governed by stringent laws like R.A. No. 6425.
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