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. The Regional Trial Court convicted Dela Cruz. On appeal, the Court of Appeals affirmed the conviction. Dela Cruz now appeals to the Supreme Court, arguing that his constitutional right to confront the witnesses against him was violated by the admission of the unobjected-to hearsay evidence.

ISSUE

Whether the failure of the defense counsel to object to the admission of hearsay evidence constitutes a waiver of the right to confront witnesses, thereby barring its raising for the first time on appeal.

RULING

No. The right to confront witnesses is a fundamental constitutional right. While the general rule is that failure to object to evidence during trial constitutes a waiver of any objection, this rule admits of exceptions. A constitutional right, such as the right to confrontation, may be raised at any stage of the proceedings, even for the first time on appeal, if its consideration is necessary to prevent a miscarriage of justice. The Court finds that the admission of the critical hearsay evidence, despite the lack of objection, deprived the accused of a fair trial. The conviction is REVERSED and SET ASIDE. The accused is ACQUITTED on reasonable doubt.