Macasiray v. People
REITERATIONFacts
1. The Antecedents: The underlying dispute concerns the murder of Johnny Villanueva on February 9, 1986. The petitioners, Melecio Macasiray, Virgilio Gonzales, and Benedicto Gonzales, are the accused in the criminal case. 2. Procedural History: The prosecution in the Regional Trial Court (RTC) sought to introduce an extrajudicial confession by Benedicto Gonzales (Exhibit B) and a transcript of preliminary investigation statements by Benedicto Gonzales (Exhibit D), both allegedly made without the assistance of counsel. The RTC initially sustained the defense's objections to the admissibility of these documents on April 14, 1988, and again on October 17, 1988, when the prosecution attempted to use them as rebuttal evidence to impeach Benedicto Gonzales's credibility. The private respondent appealed this decision to the Court of Appeals (CA). 3. The Petition: The petitioners are seeking a review of the CA's decision, which reversed the RTC's ruling and declared the extrajudicial confession and preliminary investigation transcript admissible. The CA found that the defense had waived their objections to the admissibility of these documents, either by failing to object during the prosecution's presentation of evidence or by introducing the confession as part of their own evidence-in-chief. The petitioners argue that their objections were timely made at the formal offer of evidence and that they did not waive their right to object by failing to object earlier or by questioning Benedicto Gonzales about the documents during the defense's presentation of evidence, as this was done to deny their contents.
Issue(s)
Whether the petitioners waived their objection to the admissibility of the extrajudicial confession and the transcript of the preliminary investigation by failing to object when they were marked and identified during the prosecution's presentation of evidence. Whether Benedicto Gonzales introduced his extrajudicial confession as part of the defense's evidence-in-chief. Whether the extrajudicial confession and the transcript of the preliminary investigation could be used for impeachment purposes despite their initial exclusion.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals and reinstated the orders of the Regional Trial Court dated April 14, 1988, and October 17, 1988. The extrajudicial confession and the transcript of the preliminary investigation were declared inadmissible.
Ratio Decidendi
On the issue of waiver of objection: The Court held that objections to the admissibility of documentary evidence must be made at the time the evidence is formally offered, not when it is merely marked or identified. The petitioners correctly objected when the prosecution formally offered the documents at the conclusion of its presentation of evidence. Therefore, they did not waive their objection by failing to object earlier. The Court cited Interpacific Transit, Inc. v. Aviles and Quebral v. Court of Appeals to support the principle that objection must be made at the time of formal offer. On whether Benedicto Gonzales introduced his confession as defense evidence: The Court found that the defense did not introduce the extrajudicial confession as part of its evidence-in-chief. While Benedicto was questioned about the confession, it was in the context of denying its contents, especially after the RTC had already declared it inadmissible. The defense did not mark the confession as its exhibit, which indicated it did not adopt it as evidence. Thus, the CA erred in ruling that the defense waived its objection by introducing the confession. On the use of the documents for impeachment: The Court noted that there was no need to impeach Benedicto's credibility regarding the confession and transcript because they had already been excluded as evidence by the RTC. The defense's questioning of Benedicto about these documents was to deny their contents, not to use them as evidence. Therefore, they could not be admitted even for impeachment purposes, as there was no existing testimony to impeach concerning these specific documents after their exclusion.
Main Doctrine
Objections to the admissibility of documentary evidence must be made at the time it is formally offered, not when it is merely marked or identified. Failure to object at the formal offer constitutes a waiver of the objection. Furthermore, a party cannot claim that an evidence was introduced by the opposing party when it was the party itself that presented the same during its turn to present evidence, even if the purpose was to deny its contents.