G.R. No. 129211 ; October 2, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO RODRIGUEZ Y CULO and LARRY ARTELLERO Y RICO, accused, LARRY ARTELLERO Y RICO, accused-appellant.

FACTS

On October 11, 1991, the body of security guard Ramon Matias was discovered inside the Far East Bank and Trust Company in Manila. He was hogtied and bore 32 stab wounds. The bank’s emergency vault showed chisel marks, and several firearms were missing. Police investigation revealed an ongoing construction at the bank’s upper floors. Construction workers Larry Artellero and Wilfredo Rodriguez, who had access to the bank after hours, became suspects. Police found reddish stains on Artellero’s pants and Rodriguez’s shirt. Rodriguez later executed a sworn statement confessing that he, Artellero, and others killed Matias.
Both accused were charged with Robbery with Homicide but were convicted of Murder by the Regional Trial Court. They appealed, but Rodriguez later withdrew his appeal. Artellero continued his appeal, arguing the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the guilt of appellant Larry Artellero and co-accused Wilfredo Rodriguez for the crime of Murder was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted both accused. The prosecution’s evidence was insufficient to establish guilt beyond reasonable doubt. The circumstantial evidence—the accused’s access to the bank and the bloodstains on clothing—did not constitute an unbroken chain leading to the inescapable conclusion of their guilt. The blood type on Rodriguez’s clothing matched his own, rendering it inconclusive. Critically, Rodriguez’s extrajudicial confession was inadmissible against Artellero. A confession is binding only on the confessant and is considered hearsay against a co-accused. The Court found no other competent evidence directly linking Artellero to the crime. The totality of the prosecution’s evidence failed to overcome the constitutional presumption of innocence.
Furthermore, pursuant to Rule 122, Section 11(a) of the Rules of Court, an appeal by one accused benefits a co-accused who did not appeal if the judgment is favorable and applicable. Since Artellero’s acquittal was based on the insufficiency of evidence linking both accused to the crime, this favorable judgment was equally applicable to Rodriguez. Therefore, the Court acquitted both individuals and ordered their immediate release.