G.R. No. 109943 September 20, 1995
People of the Philippines, vs. Jose Salazar and Carlito Sanchez

FACTS

On March 27, 1991, an Allied Bank armored van was blocked and fired upon by heavily armed men along Quirino Highway in Novaliches, Quezon City. Security guards Nestor Boticario, Rodolfo Donasales, and Romeo Emnacin were wounded, and bank teller Rowena Lopez was present. The assailants took a bag of coins and a service shotgun. Boticario later died from his injuries. While recovering in the hospital, Emnacin described the perpetrators to police. Based on this information and intelligence linking the accused to other robberies, police arrested Jose Salazar, who then implicated Carlito Sanchez as a co-conspirator.
Both accused were charged with Robbery with Homicide and Physical Injuries. They pleaded not guilty and were granted bail after a hearing. The trial court convicted both accused, sentencing them to reclusion perpetua. Only Carlito Sanchez appealed, arguing that the trial court erred in giving credence to Emnacin’s identification and in relying on the extrajudicial confession of his co-accused, Jose Salazar, to establish his guilt.

ISSUE

The core issue is whether the prosecution proved the guilt of appellant Carlito Sanchez beyond reasonable doubt, particularly regarding his identification as a participant and the admissibility of his co-accused’s extrajudicial statements against him.

RULING

The Supreme Court ACQUITTED appellant Carlito Sanchez. The conviction was based primarily on the testimony of Romeo Emnacin, who identified Sanchez as one of the assailants. However, the Court found Emnacin’s identification unreliable. His initial description to police did not name Sanchez, and he only identified him in court months later after Sanchez had been arrested based on Salazar’s statement. The Court ruled that while eyewitness identification is admissible, it must be credible and free from doubt. Here, the identification was tainted, as it appeared to be an afterthought influenced by the police investigation stemming from Salazar’s confession.
Crucially, the Court emphasized that the extrajudicial confession of co-accused Jose Salazar, which implicated Sanchez, is admissible only against Salazar himself. Under the res inter alios acta rule, the rights of a party cannot be prejudiced by the declarations of another. Salazar’s confession is hearsay as to Sanchez and cannot be used as evidence to establish Sanchez’s participation in the crime. Without the tainted identification and with the inadmissible confession, the prosecution’s evidence against Sanchez collapsed. The constitutional presumption of innocence prevailed, as the evidence failed to meet the standard of proof beyond reasonable doubt.