GR L 7892; (November, 1912) (Digest)
G.R. No. L-7892, November 5, 1912
THE UNITED STATES vs. SO FO
FACTS
Internal Revenue Agents Best and Sargan, along with other agents, searched a bakery at 178 Santo Cristo. In a coal pile at the rear of the building, they found a can of opium. When Agent Best held up the can and asked who owned it, the defendant So Fo, an employee at the bakery, immediately stated, “It is mine.” Agent Sargan also asked him in Tagalog, and So Fo again confirmed ownership. At trial, So Fo denied making these statements and claimed the opium belonged to another person, Tan Quin Chioc, who testified that he had placed the opium in the coal pile and that it was his. So Fo was convicted of violating the Opium Law ( Act No. 1761 , sec. 31) and sentenced to pay a fine of P300 with subsidiary imprisonment in case of insolvency.
ISSUE
Whether an uncorroborated extrajudicial confession, later denied at trial, is sufficient to sustain a conviction beyond a reasonable doubt.
RULING
Yes. The Supreme Court affirmed the conviction, holding that a voluntary extrajudicial confession, even if later denied, constitutes strong evidence of guilt. The Court cited Hopt v. People of Utah, where the U.S. Supreme Court ruled that a deliberate, voluntary confession is among the most effectual proofs in law, deserving of high credit as it is presumed to flow from a strong sense of guilt. The Court found that the agents’ testimonythat So Fo confessed in Tagalog to owning the opiumwas credible and that his confession was made freely. The subsequent denial at trial did not invalidate the confession’s probative value. The judgment was affirmed, with costs against So Fo.
Separate Concurring Opinion (Justice Torres):
Justice Torres concurred, noting that the extrajudicial confession was corroborated by circumstantial evidence: So Fo frequented the premises as an employee, and the opium was found within the yard of the house he occupied. This corroboration reinforced the confession’s reliability and supported the finding of guilt beyond reasonable doubt.
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