GR 111193; (January, 1997) (Digest)
G.R. No. 111193 January 28, 1997
People of the Philippines vs. Wilfredo Lara, et al.
FACTS
In the early morning of December 8, 1987, armed men entered the house of Estrellita Guzman in Pasig, resulting in her death from stab wounds and the robbery of household items. The domestic helper, Arlene Tuyor, was tied up and saw accused Ferdinand “Jojo” Suarez with the masked intruders. Initial police investigation suggested forced entry through the kitchen door. However, NBI investigator Atty. Salvador Ranin later determined that the kitchen door’s dead bolt lock could only be opened from inside, indicating insider involvement.
Ferdinand Suarez, the victim’s son-in-law living in the house, initially gave a statement to the police claiming he was also a bound victim. After failing a polygraph test and confronted with evidence, Suarez executed a sworn statement before the NBI confessing his participation. He admitted that he conspired with Loreto Reyes and others, providing them with keys to have duplicates made and disengaging the locks on the night of the crime to facilitate their entry. His confession implicated several individuals, including appellant Wilfredo Lara.
ISSUE
The core issue is whether the extrajudicial confession of co-accused Ferdinand Suarez, made without an opportunity for cross-examination, can be used as sufficient evidence to convict his co-accused, Wilfredo Lara.
RULING
No. The Supreme Court acquitted Wilfredo Lara, applying the established rule that the extrajudicial confession of one accused is not admissible against his co-accused. The Court explained that such a confession is considered hearsay against the others, as it was made without the co-accused being present and without the latter having the opportunity to cross-examine the declarant. The constitutional right of the accused to confront witnesses against them is violated if such an unconfronted confession is used for conviction.
The Court emphasized that the prosecution’s case against Lara rested almost entirely on Suarez’s uncorroborated confession. There was no other independent evidence, such as positive identification or physical evidence, directly linking Lara to the crime. While Suarez’s confession may be used against him, it cannot, by itself, sustain the conviction of his co-accused. The prosecution failed to prove Lara’s guilt beyond a reasonable doubt with competent and credible evidence. Consequently, the Court reversed the trial court’s decision as to Lara and ordered his acquittal.