G.R. No. 500: September 16, 1902
THE UNITED STATES, complainant-appellee, vs. LEOCADIO TANJUANCO, ET AL., defendants-appellants.

FACTS:
Leocadio Tanjuanco and Domingo Bernardo were charged with the crime of robbery en cuadrilla (robbery by a band). It was alleged that they, along with seven other armed individuals, tied up Antonio Capistrano, Benito Capistrano, Victoriano de la Cruz, and Baldomero de Vera, and carried away four carabaos and one mare belonging to Antonio Capistrano. Domingo Bernardo died in prison. The Court of First Instance convicted Leocadio Tanjuanco and sentenced him to eight years of presidio mayor. During the trial, the prosecution introduced into evidence a certified copy of the proceedings of a meeting of the municipal council of Angat, which certified that an investigation by residents concluded Tanjuanco was a man of bad character, notorious for acts including robbery, theft, and poisoning during the Spanish regime and up to the time of prosecution.

ISSUE:
Whether the Court of First Instance erred in admitting as evidence the certified proceedings of the municipal council regarding the defendant’s bad character.

RULING:
Yes. The Supreme Court reversed the conviction and remanded the case for a new trial. The Court held that the admission of the municipal council’s proceedings violated the defendant’s right under Section 15 of General Orders, No. 58 (the then governing procedural law), which guaranteed an accused in all criminal prosecutions the right “to be confronted by and to cross-examine the witnesses against him.” The document contained hearsay statements about the defendant’s character and past conduct without affording him the opportunity to confront and cross-examine the individuals who made those assertions. While such evidence might have been admissible under prior Spanish procedure (citing the Auto Acordado of September 4, 1860), it was inadmissible under the new law in force at the time of the trial.