People v. Bon
REITERATIONFacts
The Antecedents: Virgilio Bon and Alejandro Jeniebre, Jr. were charged with violating Section 68 of PD 705, as amended, for allegedly conspiring, confederating, and mutually helping one another to cut, gather, and manufacture into lumber four narra trees, one cuyao-yao tree, and one amugis tree, valued at approximately P25,000.00, without the owner's consent and necessary permits. The owner, Teresita Dangalan-Mendoza, administered her land through Virgilio Bon. Upon receiving information of stolen trees, an investigation was conducted, revealing six tree stumps. Virgilio Bon allegedly admitted to ordering the cutting of the trees. Oscar Narvaez testified that he sawed the trees upon instruction of Alejandro Jeniebre, Jr. A CENRO Officer estimated the lumber produced at 4,315 board feet, valued at P25,376.00. Procedural History: The Regional Trial Court (RTC) convicted Virgilio Bon and Alejandro Jeniebre, Jr. Rosalio Bon was acquitted. The Court of Appeals (CA) affirmed the conviction of Virgilio Bon with modification of the penalty and acquitted Alejandro Jeniebre, Jr. The CA found that Virgilio Bon admitted ordering the cutting of trees and later asked for forgiveness. The CA ruled that circumstantial evidence was sufficient for conviction. The CA acquitted Jeniebre, Jr. based on the res inter alios acta rule and lack of corroborating evidence. The Petition: Virgilio Bon filed a Petition for Review, challenging the admissibility of his alleged extrajudicial admission, the credibility and sufficiency of the prosecution witnesses' testimonies, and the constitutionality of admitting his admission.
Issue(s)
Whether hearsay testimony, denied by the alleged author under oath, is admissible. Whether hearsay testimony allegedly made to potential prosecution witnesses, not police operatives or media, is admissible against the author as a voluntary statement against interest. Whether the testimonies of prosecution witnesses regarding the petitioner's admission of guilt should be given high credence, considering the possibility of witnesses lying. Whether the extrajudicial admission made by the petitioner is constitutionally admissible in evidence against him.
Ruling
The Supreme Court affirmed the Court of Appeals' decision with modification regarding the penalty. Petitioner Virgilio Bon was sentenced to suffer an indeterminate penalty of imprisonment ranging from seven (7) years, four (4) months and one (1) day of prision mayor as minimum, to eleven (11) years, six (6) months and twenty-one (21) days of prision mayor as maximum.
Ratio Decidendi
On Whether hearsay testimony, denied by the alleged author under oath, is admissible: The Court held that testimony of what one heard a party say is not necessarily hearsay. It is admissible not to prove the truth of the statement, but that the statement was actually made. The witnesses, Julian Lascano and Manuel Dangalan, testified to facts derived from their own perception, having been present when petitioner allegedly made the admission. The fact that the utterance was made by the petitioner is relevant, and evidence of such a statement is primary, not secondary. Furthermore, the Court noted that petitioner failed to object to the testimony at the time it was offered, thereby waiving his right to do so. The admission was also considered an exception to the hearsay rule as it falls under Section 26 of Rule 130, the act or declaration of a party as to a relevant fact being admissible against him. On Whether hearsay testimony allegedly made to potential prosecution witnesses, not police operatives or media, is admissible against the author as a voluntary statement against interest: The Court reiterated that statements made against one's interest are generally admissible. The testimony of Lascano and Dangalan regarding petitioner's admission was admissible because it was a statement made by a party against his own interest, falling under Section 26 of Rule 130. The Court emphasized that the admission was not made during a custodial investigation and was not elicited by law enforcement officers. Therefore, the constitutional safeguards of Miranda rights were not applicable. The spontaneous statement given in an ordinary manner, not through questioning by authorities, does not require the presence of counsel. On Whether the testimonies of prosecution witnesses regarding the petitioner's admission of guilt should be given high credence, considering the possibility of witnesses lying: The Court affirmed the long-standing rule that the factual findings and credibility assessments of the trial court, and subsequently the Court of Appeals, deserve respect. The Supreme Court refrains from disturbing these findings unless there are glaring errors or a gross misapprehension of facts. In this case, the CA sustained the trial court's assessment of the credibility of the prosecution witnesses, and the Supreme Court found no reason to depart from this rule, thus affirming their credibility. On Whether the extrajudicial admission made by the petitioner is constitutionally admissible in evidence against him: The Court ruled that the admission was constitutionally admissible. It clarified that the admission was not made during a custodial investigation, which is defined as questioning initiated by law enforcement officers after a person has been taken into custody. The inquiry conducted by Manuel Dangalan, with the assistance of barangay tanods, was not a custodial investigation. Therefore, the constitutional guarantees under Section 12(1) of Article III of the Constitution (Miranda rights) were not applicable. Moreover, the Court noted that the conviction was not based solely on the admission but on the confluence of circumstantial evidence pointing to guilt beyond reasonable doubt.
Main Doctrine
Testimony regarding an extrajudicial admission is not hearsay if the witness perceived the statement being made, as the fact of the utterance itself is relevant. Furthermore, such admissions are admissible against the declarant under the rules on evidence, and constitutional safeguards for custodial investigations do not apply to spontaneous statements made outside of such context.