"The Court of Appeals emphasized that the prohibition against custodial investigation conducted without the assistance of counsel does not extend to a person in a police line up. This particular stage of an investigation where a person is asked to stand in a police line up has been held to be outside the mantle of protection of the right to counsel because it involves a general inquiry into an unsolved crime and is purely investigatory in nature. It has been held that identification without the presence of counsel at a police line up does not preclude the admissibility of in-court identification. "
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE,
VS.
EDUARDO GOLIDAN Y COTO-ONG, FRANCIS NACIONALES Y FERNANDEZ, AND TEDDY OGSILA Y TAHIL, ACCUSED, EDUARDO GOLIDAN Y COTO-ONG AND FRANCIS NACIONALES Y FERNANDEZ, ACCUSED-APPELLANTS.
G.R. No. 205307, January 11, 2018.
https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/1/63799
