LAW ON EVIDENCE | PEOPLE VS. ALEGRE, ET AL., L-30423, NOV. 7, 1976
PEOPLE VS. ALEGRE, ET AL.,
L-30423, NOV. 7, 1976
FACTS The case involves the death of Adelina Sajo y Maravilla, whose body was found in her home. Melecio Cudillan was caught pawning a bracelet taken from the victim and confessed to his participation in the killing and robbery. In his extrajudicial confessions, he implicated several other individuals, including Jesus Medalla and Mario Comayas, who denied any involvement in the crime. During the trial, Melecio repudiated his confessions as products of compulsion and duress, and appellants argued that the lower court erred in using his confessions as evidence against them and in concluding from their alleged silence an admission of guilt. The case also involved the testimony of an inmate who claimed that the appellants admitted to him their participation in the crime.
Whether the extrajudicial confessions of Melecio Cudillan can be used as evidence and are not competent proof against appellants Ramiro Alegre and Jesus Medalla.
Whether the silence of appellants while under police custody, in the face of statements of Melecio Cudillan implicating them as his companions in the commission of the crime, could be considered as tacit admission on their part of their participation therein.
HELD
No. As a general rule, the extrajudicial declaration of an accused, although deliberately made, is not admissible and does not have probative value against his co- accused. It is merely hearsay evidence as far as the other accused are concerned. While there are recognized exceptions to this rule, the facts and circumstances attendant in the case at bar do not bring it within the purview of such exceptions.
The extrajudicial confessions of Melecio Cudillan (Exhibits "A", "A- I " to "A-6" and "F", "F-1" and "F-2"), on the basis of which the trial court was able to reconstruct how Melecio Cudillan committed the crime in question, cannot be used as evidence and are not competent proof against appellants Ramiro Alegre and Jesus Medalla, under the principle of "res inter alios acta alteri nocere non debet" there being no independent evidence of conspiracy. As a general rule, the extrajudicial declaration of an accused, although deliberately made, is not admissible and does not have probative value against his co- accused. It is merely hearsay evidence as far as the other accused are concerned. While there are recognized exceptions to this rule, the facts and circumstances attendant in the case at bar do not bring it within the purview of such exceptions. The only evidence, therefore, linking the appellants to the crime would be their purported tacit admissions and/or failure to deny their implications of the crime made by Melecio Cudillan, and/or their purported verbal confessions to Hernando Carillo, an inmate of the Pasay City jail.
No. The right or privilege of a person accused of a crime against self- incrimination is a fundamental right. It is a personal right of great importance and is given absolutely and unequivocably. The privilege against self-incrimination is an important development in man's struggle for liberty. It reflects man's fundamental values and his most noble of aspirations, the unwillingness of civilized men to subject those' suspected of crime to the cruel trilemma of self-accusation, perjury or contempt; the fear that self-incriminating statements may be obtained by inhumane treatment and abuses, and the respect for the inviolability of the human personality and of the right of each individual "to a private enclave where he may lead a private life."
