GR 137457; (November, 2001) (Digest)
G.R. No. 137457 ; November 21, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSAURO SIA y DICHOSO, JOHNNY BALALIO y DEZA, JIMMY PONCE y TOL and JOHN DOE @ PEDRO MUÑOZ (at large), accused-appellants.
FACTS
Accused-appellants Johnny Balalio and Jimmy Ponce, along with Rosauro Sia (who escaped custody) and an unidentified John Doe, were charged with Carnapping under R.A. 6539 and Murder for the killing of taxi driver Christian Bermudez and the taking of his vehicle on August 23, 1995. Bermudez’s body, wrapped in a carton, was later found in a Bulacan fishpond. At trial, only Balalio and Ponce were arraigned and tried. The prosecution’s case heavily relied on the extrajudicial confessions of the absent co-accused, Rosauro Sia, and of appellant Jimmy Ponce, which implicated all accused in the conspiracy to kill the driver and steal the taxi.
The trial court convicted Balalio and Ponce as principals by conspiracy for violation of the Anti-Carnapping Law and sentenced them to death. It awarded damages to the victim’s mother. On automatic review, the accused-appellants contended that the trial court erred in convicting them based solely on the extrajudicial confessions of their co-accused, Sia and Ponce, arguing these confessions were inadmissible against them.
ISSUE
Whether the conviction of accused-appellants Johnny Balalio and Jimmy Ponce, based principally on the extrajudicial confessions of their co-accused, is valid.
RULING
No. The Supreme Court reversed the conviction. The legal logic is anchored on the res inter alios acta rule under Section 30, Rule 130 of the Rules of Court. An extrajudicial confession is admissible only against the confessant and not against co-accused. It is considered hearsay against others and violates their constitutional right to confront and cross-examine witnesses. The prosecution failed to present any other competent evidence, such as an eyewitness account or physical evidence, directly linking Balalio and Ponce to the crime. The Court emphasized that the corpus delicti of carnapping—the taking of the vehicle with intent to gain—was not proven by evidence independent of the inadmissible confessions. Consequently, the guilt of the appellants was not established beyond reasonable doubt. The Court acquitted Johnny Balalio and Jimmy Ponce and ordered their immediate release, unless detained for another lawful cause. The case against the fugitive Rosauro Sia remained archived.