People v. Fo
REITERATIONFacts
The Antecedents: Internal revenue agents searched a bakery at 178 Santo Cristo. In a coal pile at the rear of the building, they discovered a can of opium. Upon presentation of the can, the defendant, So Fo, allegedly stated that it was his. Procedural History: The defendant was charged with violating section 31 of Act No. 1761, the Opium Law. The trial court found him guilty and imposed a fine of P300 with subsidiary imprisonment in case of insolvency, and costs. The Petition: The defendant appealed, arguing that the court erred in finding that he acknowledged ownership of the opium and that his guilt was not established beyond a reasonable doubt.
Issue(s)
Whether the defendant's alleged extrajudicial confession that the opium found was his property was established. Whether the testimony presented establishes the guilt of the appellant beyond a reasonable doubt.
Ruling
The Supreme Court affirmed the judgment of the lower court, finding the defendant guilty of violating the Opium Law. The penalty imposed was a fine of P300 with corresponding subsidiary imprisonment in case of insolvency, and costs.
Ratio Decidendi
On the issue of the defendant's alleged extrajudicial confession: The Court found that the defendant did state more than once, upon discovery of the opium, that he was the owner of the same. The two internal revenue agents testified that they spoke to the defendant in Tagalog, and he responded in the same language, indicating understanding. The Court considered these statements or confessions to have been made voluntarily. On the issue of whether guilt was established beyond a reasonable doubt: The Court addressed the proposition that an uncorroborated extrajudicial confession, later denied upon trial, might not be sufficient for conviction. Citing Hopt vs. People of Utah, the Court affirmed the principle that a confession, if freely and voluntarily made, is evidence of the most satisfactory character and constitutes the strongest evidence against the party making it. The Court held that such a confession, when deliberate and voluntary, is among the most effectual proofs in the law. The Court concluded that the judgment was strictly in accordance with the law and the evidence presented.
Main Doctrine
An uncorroborated extrajudicial confession, even if later denied upon trial, may be sufficient upon which to rest a judgment of conviction, provided it is voluntary and freely made, and is corroborated by circumstances that lend certainty to the facts confessed.