People v. De la Cruz
REITERATIONFacts
The Antecedents: On April 10, 1944, during the Japanese occupation, Atty. Pedro Sorreta was killed. The original information for murder was filed in 1947 against six accused. The appellant, Abundio de la Cruz, and co-accused Ladislao Tayo jumped bail in 1951. A co-accused, Eriberto Cenon, was tried in 1959, implicated the others, and was sentenced to life imprisonment. The appellant was arrested in 1969, 25 years after the crime and 18 years after jumping bail. An amended information was filed in 1970, charging murder with treachery and evident premeditation, and several aggravating circumstances. Procedural History: The trial court convicted Abundio de la Cruz of murder and sentenced him to death. The court considered the appellant's flight and the testimony of witnesses who placed him at the scene and implicated him in the killing and subsequent intimidation of the victim's family. The court also relied on the confession of Eriberto Cenon, a co-accused. The Petition: The accused-appellant appealed the decision, assigning errors related to the sufficiency of evidence, the establishment of conspiracy, the finding of foul play, the establishment of motive, and the imposition of the death penalty.
Issue(s)
Whether the extrajudicial confession of a co-accused, not presented in court, is admissible against the appellant. Whether the remaining evidence, excluding the inadmissible confession, is sufficient to establish the guilt of the appellant for murder beyond reasonable doubt. Whether the aggravating circumstances alleged in the amended information were sufficiently proven. Whether the appellant's flight is sufficient evidence of guilt.
Ruling
The Supreme Court reversed and set aside the judgment of the lower court, acquitting the accused-appellant Abundio de la Cruz due to insufficiency of evidence to establish his guilt beyond reasonable doubt. He was ordered to be released immediately unless held for another lawful cause.
Ratio Decidendi
On the admissibility of the co-accused's confession: The Court held that the extrajudicial confession of Eriberto Cenon, taken in 1950 and not presented in open court during the trial of Abundio de la Cruz in 1970, was inadmissible against the appellant. This is because its admission would violate the appellant's constitutional right to confrontation of witnesses. The Court emphasized that such a confession cannot be used against a co-accused unless repeated in open court or used merely as corroborative or circumstantial evidence, which was not the case here as it was the principal evidence against the appellant. The Court noted that despite knowing Cenon was serving sentence, efforts were not sufficiently exerted to bring him to testify, thus violating the principle of res inter alios alteri nocere non debet. On the sufficiency of remaining evidence: The Court found that without the inadmissible confession, the remaining evidence was insufficient to establish the appellant's guilt beyond reasonable doubt. While witnesses testified to the appellant's presence in the area and his association with the killing, none of them directly witnessed the commission of the crime. The testimonies of Tatad and Ugalde were based on what they were told by others or overheard conversations, and the testimonies of the victim's family primarily concerned acts of intimidation after the killing. The Court found the prosecution's evidence not clear, positive, and convincing enough for a capital offense. On the aggravating circumstances: The Court noted that the trial court found three aggravating circumstances (advantage of superior strength, commission at night, and commission in an uninhabited place) to be sustained by the evidence. However, since the primary evidence (the confession) was deemed inadmissible, and the remaining evidence was insufficient to prove guilt beyond reasonable doubt, the Court did not need to definitively rule on the presence and effect of these circumstances on the conviction. On the appellant's flight: The Court acknowledged that the trial court considered the appellant's flight and prolonged disappearance as indicative of guilt. However, while flight may be considered as an indication of guilt, it is not conclusive proof thereof. In this case, the Court found the other evidence insufficient to overcome the presumption of innocence, rendering the flight, by itself, insufficient to sustain a conviction.
Main Doctrine
The extrajudicial confession of a co-accused, not presented in court for cross-examination, is inadmissible against the appellant as it violates the right to confrontation, and without this confession, the remaining evidence is insufficient to establish guilt beyond reasonable doubt.