GR L 37686; (August, 1982) (Digest)
G.R. No. L-37686 August 30, 1982
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN L. ARCENAL, accused-appellant.
FACTS
Edgardo Funa was killed on September 5, 1972, in Panabo, Davao del Norte. Following the incident, security guards Benjamin Arcenal, Navy Padilla, and Ernesto Castro were arrested. Padilla executed a sworn confession stating that Castro stabbed Funa, that he (Padilla) also stabbed Funa, and that Arcenal likewise stabbed Funa with a pocket knife. Based on this confession and circumstantial evidence, the trial court convicted all three of murder.
Only Benjamin Arcenal appealed the conviction. He contended he was not a co-conspirator and did not assault Funa, insisting only Padilla and Castro were responsible. The prosecution conceded that the sole evidence directly linking Arcenal to the stabbing was the imputation within Padilla’s extrajudicial confession. Notably, Padilla later executed an affidavit of retraction, alleging Arcenal did not participate and that he (Padilla) was the principal actor.
ISSUE
Was the guilt of accused-appellant Benjamin Arcenal for the crime of murder proven beyond reasonable doubt?
RULING
No, Arcenal’s guilt was not proven beyond reasonable doubt. The Supreme Court reversed his conviction. The legal logic centers on the rules of evidence, specifically the inadmissibility of a co-accused’s extrajudicial confession against another. Padilla’s confession implicating Arcenal was admissible as evidence only against Padilla himself, not against Arcenal. This principle is fundamental, as such a confession is considered hearsay against the other accused.
The Court found no other competent evidence to corroborate Arcenal’s alleged direct participation. The circumstantial evidence of his presence with the group was insufficient to establish conspiracy or his individual criminal act. Furthermore, Padilla did not confirm the allegation against Arcenal in his court testimony; he even testified he signed his confession without reading it. Arcenal’s own testimony denied involvement and suggested no motive. Given the lack of credible, admissible evidence proving his participation beyond reasonable doubt, Arcenal was entitled to acquittal. The Court ordered his immediate release.