People v. Yatco
REITERATIONFacts
The Antecedents: An amended information was filed charging Juan Consunji, Alfonso Panganiban, and another unknown individual with conspiracy to commit murder. During the trial, the prosecution presented a witness to testify on an extra-judicial confession allegedly made by defendant Juan Consunji. Procedural History: Counsel for the co-accused Alfonso Panganiban objected to the admissibility of Consunji's confession as against Panganiban, citing it as hearsay. The trial court excluded the evidence, not on the ground of hearsay, but motu proprio, on the basis that conspiracy must first be proven by definite acts, conditions, and circumstances before any confession of the accused could be admitted to prove conspiracy. The prosecution's motion for reconsideration was denied. The Petition: The Solicitor General filed a petition for certiorari, seeking the annulment of the lower court's order completely excluding the evidence on the extrajudicial confessions of the accused Juan Consunji and Alfonso Panganiban without prior proof of conspiracy.
Issue(s)
Whether the trial court committed grave abuse of discretion in excluding the extrajudicial confessions before conspiracy was proven. Whether a trial judge can motu proprio exclude evidence on a ground not raised by the parties.
Ruling
The Court ruled that the lower court committed a grave abuse of discretion in ordering the complete exclusion of the prosecution's evidence on the alleged confessions. The order of exclusion was annulled and set aside, and the court below was directed to proceed with the trial in accordance with law.
Ratio Decidendi
On Issue 1: The Supreme Court held that the trial court erred in applying Section 12, Rule 123 of the Rules of Court to post-conspiracy confessions. This rule, which requires prior proof of conspiracy before a conspirator's statement can be used against a co-conspirator, refers only to statements made during the existence of the unlawful enterprise. Since the confessions in question were made long after the conspiracy ended, the rule was inapplicable. Applying the principle of multiple admissibility, the Court stressed that under Section 14, Rule 123, a confession is admissible against the declarant to prove his own guilt. Even if the confession is hearsay as to the co-accused, it must still be admitted as evidence against the person who made it. The complete exclusion was also premature because the confessions had not yet been formally offered in evidence, and the prosecution might have provided independent proof of conspiracy later in the trial. On Issue 2: The Court ruled that the trial judge exceeded his authority by motu proprio excluding the evidence on a ground not raised by counsel. While Panganiban's counsel objected on the ground of hearsay, the judge excluded the evidence based on the lack of prior proof of conspiracy, a ground the court raised on its own motion. The right to object is a mere privilege which parties may waive; if a ground for objection is known but not raised, the court has no power to disregard the evidence on its own. Citing Prats & Co. v. Phoenix Insurance Co., the Court emphasized that trial judges should be liberal in admitting evidence, as an unjustified exclusion in a criminal case might lead to an erroneous acquittal from which the People cannot appeal. The trial judge should instead admit the evidence conditionally and distinguish the admissible from the inadmissible during the final determination of the case.
Main Doctrine
The extrajudicial confession of an accused, freely and voluntarily made, is admissible as evidence against him, even if it may not be competent as against his co-accused or to prove conspiracy without prior proof thereof. The premature exclusion of such evidence constitutes grave abuse of discretion.