G.R. No. L-30423 November 7, 1979
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMIRO ALEGRE y CERDONCILLO, MARIO COMAYAS y CUDILLAN, MELECIO CUDILLAN y ARCILLAS, and JESUS MEDALLA y CUDILLAN, defendants-appellants.

FACTS

This is an automatic review of a conviction for Robbery with Homicide by the Court of First Instance of Rizal, which imposed the death penalty. The case stemmed from the killing of Adelina Sajo inside her Pasay City home on July 26, 1966. No eyewitnesses saw the crime. The prosecution’s case primarily rested on the extrajudicial confessions of accused Melecio Cudillan, who was apprehended while pawning stolen jewelry. In his confessions, he implicated his co-accused, appellants Ramiro Alegre, Mario Comayas, and Jesus Medalla. During the investigation, Melecio pointed to the appellants as his companions. The trial court noted that the appellants, when pointed out, merely remained silent and did not protest.
To bolster its case, the prosecution presented Sgt. Mariano Isla, who testified about the confrontation where Melecio identified the appellants, and Hernando Carillo, a fellow detainee, who claimed the appellants confessed their involvement to him while in jail. The trial court found this evidence sufficient, convicting all accused. Melecio Cudillan died during the appeal, leaving the case for review against the three surviving appellants.

ISSUE

Whether the evidence presented by the prosecution, consisting mainly of an extrajudicial confession of a co-accused and the alleged tacit admission and jailhouse confession of the appellants, is sufficient to sustain a conviction beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted the appellants. The legal logic is anchored on the constitutional right against self-incrimination and the rules on the admissibility of evidence. The trial court erred in interpreting the appellants’ silence during the police confrontation as a tacit admission of guilt. The right to remain silent is absolute and cannot be construed as an admission, especially while in police custody. This right creates a zone of privacy that the state cannot invade to the detriment of the accused.
Furthermore, the extrajudicial confession of Melecio Cudillan is inadmissible against the appellants. A confession is only binding on the confessant and not on his co-accused. It constitutes hearsay against them. With the co-accused’s confession excluded, the remaining evidence is insufficient. The testimony of Sgt. Isla merely established the act of pointing, which, coupled with the improper inference from silence, has no probative value. The testimony of detainee Carillo was deemed inherently improbable, as it was unlikely the appellants would confess to a casual acquaintance in jail while denying the crime to authorities. With no competent evidence directly proving their participation, the guilt of the appellants was not established beyond reasonable doubt, warranting acquittal.