People v Judge Ayson 175 SCRA 216 (1989)

Facts: Felipe Ramos was a ticket freight clerk of the Philippine Airlines and was allegedly involved in irregularities in the sales of plane tickets.  The PAL management notified him of an investigation to be conducted. That investigation was scheduled in accordance with PAL's Code of Conduct and Discipline, and the Collective Bargaining Agreement signed by it with the Philippine Airlines Employees' Association (PALEA) to which Ramos pertained. A letter was sent by Ramos stating his willingness to settle the amount of P76,000. The findings of the Audit team were given to him, and he refuted that he misused proceeds of tickets also stating that he was prevented from settling said amounts. He proffered a compromise however this did not ensue. Two months after a crime of estafa was charged against Ramos. Ramos pleaded not guilty. Evidence by the prosecution contained Ramos’ written admission and statement, to which defendants argued that the confession was taken without the accused being represented by a lawyer. Respondent Judge did not admit those stating that accused was not reminded of his constitutional rights to remain silent and to have counsel. A motion for reconsideration filed by the prosecutors was denied. Hence this appeal.