G.R. No. 1042 , March 9, 1903
THE UNITED STATES, complainant-appellee, vs. EXEQUIEL CASTILLO, ET AL., defendants-appellants.

FACTS:
The defendants, Exequiel Castillo and Catalino Circa, were charged in the Court of First Instance of Nueva Ecija with the crime of robbery and murder. The information alleged that in January 1900, in Carranglan, Nueva Ecija, Exequiel Castillo, who lived with his aunt Doña Joaquina de Castro, struck her on the head with a piece of wood, causing her death, with the intent to appropriate her property. He then requested Catalino Circa to bury the body, paying him ten dollars for his assistance. The trial court convicted Exequiel Castillo as the principal and sentenced him to death. It convicted Catalino Circa as an accessory after the fact and sentenced him to ten years of presidio mayor. Only Exequiel Castillo appealed the judgment.

The prosecution’s evidence against Castillo consisted entirely of the extrajudicial confessions made by his co-defendant, Catalino Circa, to various persons, and Circa’s statements made during the preliminary investigation before the provincial fiscal. During the trial, however, Catalino Circa testified for the defense, repudiating his prior confessions and denying any knowledge of the crime. The trial court nonetheless considered Circa’s prior confessions and preliminary investigation statements as evidence against both defendants and found them guilty.

ISSUE:
Whether the trial court erred in admitting the extrajudicial confessions and preliminary investigation testimony of co-defendant Catalino Circa as evidence against appellant Exequiel Castillo.

RULING:
Yes, the trial court committed a reversible error. The judgment convicting Exequiel Castillo is reversed, and he is ordered acquitted and discharged.

The Supreme Court held that the right of an accused to be confronted with the witnesses against him, as provided in Section 15 of General Orders No. 58, was denied to Exequiel Castillo. The confessions of a co-defendant made outside of court and his testimony given during the preliminary investigation are inadmissible as evidence against another defendant. Such prior testimony may only be admitted at trial under specific exceptions (e.g., if the witness is dead, insane, or cannot be found with due diligence), none of which were present in this case. Since the prosecution’s case against Castillo rested solely on this inadmissible evidence, there was no competent proof to sustain his conviction.

The Court clarified that its ruling did not affect the judgment against Catalino Circa, as he did not appeal. The confessions might have been admissible against Circa himself, but that issue was not before the Court. The acquittal of Castillo was without prejudice to the judgment against Catalino Circa.