PEOPLE V.

BRAVO
FACTS

: The decomposin
g body of nine
year old girl
Juania Anolin
!Len"len# $as
found in a%acan
lo "" na&ed'
shirless and

s&ir pulled up'

her pany
su(ed in her
mouh. )er
body$as found
abou *++
meers from her
house. The scalp
on he lef side
of her head

$asdeached
e,posing a
fracure on he
lef emporal
lobe of her s&ull.
Vaginal
e,aminaionsho$
ed fresh lacerai
on easily accep
s $o -ngers.

The cause of dea

h $as cerebralh
emorrhage.An
nformaion
for rape $ih
homicide $as -led
agains herein
accused"appellan
. )e$as arraigned
and pleaded no

guily.E%elyn' an
eigh year old
second grader
and neighbor and
cousin of he %i
cimesi-ed
ha she $as
$ih he
deceased he
nigh before she

disappeared. n
cour' E
%elynposii%ely
ideni-ed he
appellan as
he person las
seen $ih Len"len
before she $as
founddead. The o
$ner of he hous

e $here Len"len a
nd E%elyn
$ached ele
%ision' /racia0ona
han' corroboraed
E%elyn1s
esimony. The
2hief of he n
elligence 3ecion
of he 3aniago

Police 4eparmen
' Ale,ander0ico'
esi-ed in
cour ha a
he police
saion he
appellan
admied he
$as $ih he
girland he carried

her on his should

er bu he
$as so drun& h
a nigh ha
he does nor
emember $ha
he did o her. On
cross"e,aminaio
n 0ico admied
ha he did no

informhe
appellan of his
consiuional
righs o remain
silen' o
counsel and of his
righ
againsself"incri
minaion before
he appellan

made he said
admission
because according
o 0icohe
$as only
informally iner
%ie$ing
he accused
$hen he
made he

admission
and hacuso
dial
inerrogaion
proper $as
conduced by
he assigned in
%esigaor.
HELD

:5e resol%e o
ac6ui Benio
Bra%o. 3ecion
78 of Aricle
of he
79*
2onsiuione
mbodies he ma
ndaory proec
ion a(orded a p

erson under in
%esigaion fo
r hecommission
of a crime and
he correlai%e
duy of
he 3ae and
is agencies o
enforce
suchmandae.

The manle
of proecion
under his
consiuional
pro%ision co%ers
he period
fromhe ime a
person is a&en
ino cusody for
in%esigaion of

his possible
paricipaion in
hecommission of
a crime or from
he ime he is
singled ou as a
suspec in he
commission of
acrime alhough
no ye in

cusody. La$
enforcemen
agencies are
re6uired o
e(eci
%elycommunica
e he righs
of a person under
in%esigaion
and o insure

ha i is fullyun
dersood. Any
informaion or
admission gi%en
by a person $hile
in cusody $hich
mayappear harml
ess or innocuous
a he ime $i
hou he co

mpeen assis
ance of aninde
penden counsel
should be sruc&
do$n
as inadmissible.
has been
held' ho$e%er'
haan
admission made

o ne$s
reporers or o
a con-dan of
he accused is
no co%ered by
hee,clusionary
rule. The accused
$as under arres
for he rape and
&illing of Juania

Anolin and anys

aemen
allegedly made by
him peraining
o his possible
compliciy in
he crime
$ihouprior
noi-caion of
his

consiuional
righs is
inadmissible in e
%idence. The
policeman1sappar
en aemp
o circum%en
he rule by
insising ha
he admission

$as made during

an;informal al&;
prior o
cusodial in
%esigaion
proper is no
enable. The
appellan $as
noin%ied o
he

police saion
as par of a gen
eral in6uiry for
any possible lead
o heperper
aors of he
crime under in
%esigaion.