Galman vs.

Pamaran Issue: Whether the right against self-incrimination extends

to testimonies given before the Agrava board and not to an
Topic: Right against self-incrimination
investigating officer.
Ruling: Yes.
Doctrine: The privilege of the right against self-
Ratio: The privilege has consistently been held to extend
incrimination and the right to due process extends to all
to all proceedings sanctioned by law and to all cases in
proceedings sanctioned by law and to all cases in which
which punishment is sought to be visited upon a witness,
punishment is sought to be visited upon a witness, whether
whether a party or not. If in a mere forfeiture case where
a party or not.
only property rights were involved, "the right not to be
Facts: Eight private respondents, who were initially compelled to be a witness against himself" is secured in
witnesses in the Fact Finding Board, were charged with favor of the defendant, then with more reason it cannot be
the murder of Ninoy Aquino and Rolando Galman. The denied to a person facing investigation before a Fact
Prosecution marked and offered as part of its evidence the Finding Board where his life and liberty, by reason of the
individual testimonies of private respondents before the statements to be given by him, hang on the balance.
Fact Finding Board. Private respondents objected to the
admission of said exhibits on the ground that they were
denied the right against self-incrimination and right to due
process. Sandiganbayan applied the Exclusionary Rule
and admitted all the evidence offered by the prosecution
except the testimonies and/or other evidence produced by
the private respondents. The Court affirmed the
Sandiganbayan’s resolution and held that the testimonies
were not admissible as evidence. When the private
respondents were summoned and gave their testimonies
before the Board, they were denied the right to remain
silent. They were compelled to testify or be witness against
themselves.