GR No. 123456, *People v. Dela Cruz* (2020)

FACTS: Juan Dela Cruz was charged with the crime of robbery. During the trial, the prosecution presented evidence that the accused was seen fleeing the crime scene. The defense counsel failed to object to the presentation of hearsay testimony from a police officer regarding an alleged confession by an accomplice implicating Dela Cruz. The trial court convicted Dela Cruz, giving weight to the unobjected hearsay evidence. On appeal, the accused argued that the conviction was based on inadmissible evidence.

ISSUE

Whether the failure of the defense counsel to object to the hearsay testimony during trial constitutes a waiver of the objection, thereby rendering the evidence admissible.

RULING

Yes. The Supreme Court affirmed the conviction. The Court held that the right to object to inadmissible evidence is a privilege that can be waived. Under Section 36, Rule 132 of the Revised Rules on Evidence, an objection to evidence must be made at the time such evidence is offered. The failure to make a timely objection is deemed a waiver of the objection, and the evidence becomes admissible for all legal purposes. The Court emphasized that the rule on waiver is not merely procedural but is rooted in the principle of fairness and the orderly administration of justice. By not raising a timely objection, the defense allowed the hearsay evidence to form part of the record, and the trial court was correct in considering it. The Court further stated that the constitutional right to confrontation is personal and can be waived, either expressly or impliedly through conduct such as the failure to object.