G.R. No. L-52038. May 31, 1982.
The People of the Philippines, plaintiff-appellee, vs. Crispin Royo and Mariano Maglente, accused-appellants.

FACTS

The case involves the murder of Carmen Huelva-Lim Chan, whose body, bearing signs of manual strangulation and multiple stab and blunt force wounds, was discovered in her Binondo, Manila home on October 12, 1977. Accused-appellant Crispin Royo, a former household helper of the victim, was arrested the following day. He executed two confessions—first handwritten, then typewritten—wherein he admitted to stabbing Chan. In these confessions, Royo implicated his co-accused, Mariano Maglente, also a former houseboy of the family, alleging that Maglente suggested the killing due to their resentment over poor working conditions and provided the knife. Royo further claimed Maglente entered the scene and struck the victim with a printing press roller. Royo later reenacted the crime. At trial, however, both Royo and Maglente pleaded not guilty. Royo subsequently executed another affidavit recanting his confessions and exculpating Maglente, claiming his earlier statements were coerced.

ISSUE

The primary issues are: (1) whether Royo’s extrajudicial confessions were voluntarily executed and admissible as evidence against him; and (2) whether these confessions, along with other evidence, are sufficient to sustain Maglente’s conviction.

RULING

The Supreme Court affirmed Royo’s conviction but acquitted Maglente. Regarding Royo, the Court upheld the admissibility of his confessions. It found they were given voluntarily, knowingly, and intelligently, constituting a valid waiver of his constitutional rights to remain silent and to counsel. The Court noted the second, typewritten confession contained explicit warnings and a waiver, which Royo acknowledged under oath. The spontaneity was further evidenced by the verbatim inclusion of Visayan words in his Tagalog statements, indicating the investigator did not alter his answers. Consequently, these admissible confessions provided ample basis for his conviction for murder.
For Maglente, the Court ruled differently. Royo’s confessions, being extrajudicial, are hearsay and res inter alios acta (an act done by others) as to Maglente, and thus inadmissible against him. Royo did not testify in court to affirm the contents of these confessions; instead, he later recanted them. Without these confessions, the remaining evidence—principally the testimony of the victim’s daughter who merely saw Maglente in the vicinity on the morning of the crime—was insufficient to prove his guilt beyond reasonable doubt. The Solicitor General himself recommended acquittal. Therefore, the judgment was reversed as to Maglente, and he was acquitted due to the inadmissibility and insufficiency of the evidence linking him to the crime.