GR No. 123456, January 1, 2023
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Homicide. The prosecution presented eyewitness testimony and forensic evidence. During trial, the defense counsel failed to object to the admission of allegedly hearsay statements from a witness who did not testify. The Regional Trial Court convicted Dela Cruz. On appeal, the Court of Appeals affirmed the conviction, ruling that the failure to timely object constituted a waiver of the right to challenge the evidence. Dela Cruz now appeals to the Supreme Court, arguing that the admission of the hearsay evidence violated his constitutional right to confront the witness against him and that his counsel’s failure to object constituted ineffective assistance of counsel.

ISSUE

Whether the Court of Appeals erred in affirming the conviction despite the admission of hearsay evidence, and whether the accused was deprived of his right to effective assistance of counsel.

RULING

No. The petition is denied. The Court of Appeals did not err.

The right to confront witnesses is not self-executing; it must be invoked timely through an objection. The failure of counsel to object to the admission of hearsay evidence during trial constitutes a waiver of the right to object on that ground on appeal. While the right to counsel is fundamental, the right to effective counsel is not a guarantee of errorless counsel. For a claim of ineffective assistance of counsel to prosper, the appellant must show that counsel’s performance was grossly negligent and that such negligence prejudiced the defense. In this case, the alleged error in strategythe decision not to objectdoes not, by itself, amount to gross negligence absent a showing of a clear and prejudicial impact on the outcome. The prosecution’s evidence, independent of the unchallenged hearsay, was sufficient to establish guilt beyond reasonable doubt. Therefore, the conviction stands.