G.R. No. L-25668 May 2, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMAN JUGILON, AMANCIO BALATAYO and CRISPIN JAVIER, defendants-appellants.

FACTS

On the night of May 26, 1960, an aged couple, Estanislao Jugilon and Emiliana Puyod, were beaten to death in their house in Sapang Dalaga, Misamis Occidental, and approximately P800.00 was taken. The police investigation initially yielded no arrests. On October 28, 1962, Crispin Javier was arrested for theft of coconuts and was investigated about the robbery-killing. He signed an affidavit (Exhibit “H”) dated October 30, 1962, stating that Roman Jugilon and Amancio Balatayo committed the robbery and killing while he waited downstairs, and that Roman later warned him not to tell anyone. Subsequently, Amancio Balatayo and Roman Jugilon were arrested. Amancio executed an affidavit (Exhibit “I”) dated November 2, 1962, stating that Roman had proposed killing the old couple and later informed him they were dead and that P800.00 was taken. Amancio later signed an additional affidavit (Exhibit “I-4”) stating he heard Roman confess to the killing before the Chief of Police. At the trial, all three accused repudiated their affidavits, claiming they were obtained through force and intimidation. Crispin Javier and Amancio Balatayo also interposed alibi. The Court of First Instance found all three guilty based on their extrajudicial confessions and proof of corpus delicti, sentencing them to reclusion perpetua. They appealed.

ISSUE

Whether the extrajudicial affidavits of the accused constitute admissible confessions sufficient to sustain their conviction for robbery with double homicide beyond reasonable doubt.

RULING

No. The judgment of conviction is reversed, and the accused-appellants are acquitted on reasonable doubt. The affidavits do not constitute admissible confessions against the declarants or their co-accused. Crispin Javier’s affidavit exculpates him, as it states he was merely present and did not participate. Amancio Balatayo’s affidavits do not contain a positive admission of his own guilt; they primarily implicate Roman Jugilon. Roman Jugilon did not execute any affidavit admitting guilt, and his alleged verbal statements do not constitute a clear confession. Furthermore, the affidavits of Crispin and Amancio are hearsay as to Roman Jugilon and cannot be used against him, as they were not made in the course of the conspiracy’s execution but long after. With no other evidence presented to prove guilt beyond reasonable doubt, the conviction cannot stand.