GR L 37398; (June, 1974) (Digest)
G.R. No. L-37398 June 28, 1974
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROSARIO CABRERA and CONRADO VILLANUEVA, defendants, CONRADO VILLANUEVA, defendant-appellant.
FACTS
The case involves a robbery-holdup with homicide that occurred on January 17, 1972, in Valenzuela, Bulacan. The victim, jeep driver Luis de la Cruz, was found abandoned with fatal stab wounds. His jeep, valued at P8,000.00, was stolen. The police investigation led to the arrest of accused Rosario Cabrera, who had hired the victim’s jeep on the night of the crime. Cabrera executed an extrajudicial confession on January 20, 1972, wherein she implicated appellant Conrado Villanueva as the mastermind of the crime, alleging that he, along with two unidentified companions, carried out the robbery and killing. At trial, the prosecution presented this confession as key evidence. Both Cabrera and Villanueva opted not to testify or present evidence. The trial court convicted both accused, sentencing them to life imprisonment. Only Villanueva appealed.
ISSUE
The core issue is whether the extrajudicial confession of co-accused Rosario Cabrera is admissible as evidence against appellant Conrado Villanueva to sustain his conviction.
RULING
The Supreme Court reversed the conviction and acquitted appellant Conrado Villanueva. The legal logic centers on the inadmissibility of a co-conspirator’s confession made after the conspiracy has ended. The Court applied Section 27, Rule 130 of the Rules of Court, which states that the act or declaration of a conspirator is only admissible against a co-conspirator if it was made during the existence of the conspiracy and relates to it. Crucially, such a declaration cannot itself be the sole proof of the conspiracy; the conspiracy must first be established by independent evidence.
In this case, Cabrera’s confession was executed on January 20, 1972, two days after the crime and while she was already in police custody. At this point, any alleged conspiracy had long ceased. Therefore, her statements were not made “during the existence” of the conspiracy as required by law. Furthermore, the prosecution presented no other competent evidence to prove Villanueva’s participation or to establish the conspiracy independently of Cabrera’s inadmissible confession. Her confession was the only evidence linking Villanueva to the crime. With the confession ruled inadmissible against him and in the absence of any other corroborating proof, the evidence against Villanueva was insufficient to prove his guilt beyond reasonable doubt. Consequently, the Court had no alternative but to order his acquittal.