G.R. No. 110290. January 25, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JAIME “JIMMY” AGUSTIN, WILFREDO “SONNY” QUIANO, MANUEL “JUN” ABENOJA, JR., and FREDDIE “BOY” CARTEL, accused. JAIME “JIMMY” AGUSTIN, accused-appellant.

FACTS

Accused Jaime Agustin was charged with murder for the deaths of Dr. Napoleon Bayquen and Anna Theresa Francisco, frustrated murder, and attempted murder, all allegedly committed on September 6, 1986, in Baguio City. The cases were consolidated and tried jointly. Only Agustin and Wilfredo Quiño were arrested, but Quiño escaped custody before arraignment. After trial, the Regional Trial Court acquitted Agustin of frustrated and attempted murder but convicted him of two counts of murder, qualifying the crimes with treachery and appreciating the aggravating circumstances of evident premeditation and price or reward. He was sentenced to reclusion perpetua for each count.
The prosecution evidence established that the victims were ambushed while in their vehicle. Wilfredo Quiño, who was later apprehended, confessed to being the triggerman and implicated Agustin, among others, during an investigation before the City Fiscal. Agustin was subsequently arrested. During his own investigation, also before the City Fiscal and with the assistance of counsel from the Integrated Bar of the Philippines, Agustin initially denied involvement but later admitted to driving the getaway car used in the shooting, confirming Quiño’s role as the shooter.

ISSUE

The core issue is whether the extrajudicial confession of co-accused Wilfredo Quiño, which implicated appellant Agustin, is admissible as evidence against Agustin.

RULING

The Supreme Court reversed the conviction and acquitted Jaime Agustin. The Court meticulously applied the rule on the admissibility of extrajudicial confessions. An extrajudicial confession is admissible only against the confessant and not against co-accused. It constitutes hearsay against the latter, violating their constitutional right to confront and cross-examine witnesses. The trial court erred in utilizing Quiño’s confession to establish Agustin’s participation in the conspiracy.
The prosecution’s case against Agustin rested almost entirely on this inadmissible confession. While Agustin himself made an admission about driving a car, this statement, absent Quiño’s confession, was insufficient to prove conspiracy to commit murder. His admission did not detail any agreement to kill, establish his knowledge of the criminal design, or show concerted action. Without the illicit use of Quiño’s statement, the evidence failed to prove Agustin’s guilt beyond reasonable doubt. The Court emphasized that conspiracy must be proven by clear and convincing evidence of a common criminal purpose, which was not met here. Consequently, Agustin was acquitted on grounds of reasonable doubt.