People v Garchitorena

FACTS:  Some employees of the post office were investigated by the chief postal service officer in connection with missing postage stamps.  During interrogation, they submitted sworn statements.  The prosecution presented the sworn statements as evidence.  Accused claimed that their sworn statements were not admissible in evidence since they were not assisted by counsel.

HELD:  The right to counsel is not imperative in administrative investigation because such inquiries are conducted merely to determine whether there are facts that merit disciplinary measures against erring public officers.