The Supreme Court of the Philippines ruled that the extrajudicial confession of Adelberto Camota was inadmissible as evidence against his co-accused Solito Tena. According to Section 28 of the Rules of Court, the rights of a party cannot be prejudiced by an act or declaration of another unless a conspiracy is proved. In this case, there was no evidence presented of a conspiracy between Camota and Tena. As the extrajudicial confession was the only evidence linking Tena to the crime, and it was deemed inadmissible, the court found Tena not guilty of robbery with homicide.
The Supreme Court of the Philippines ruled that the extrajudicial confession of Adelberto Camota was inadmissible as evidence against his co-accused Solito Tena. According to Section 28 of the Rules of Court, the rights of a party cannot be prejudiced by an act or declaration of another unless a conspiracy is proved. In this case, there was no evidence presented of a conspiracy between Camota and Tena. As the extrajudicial confession was the only evidence linking Tena to the crime, and it was deemed inadmissible, the court found Tena not guilty of robbery with homicide.
The Supreme Court of the Philippines ruled that the extrajudicial confession of Adelberto Camota was inadmissible as evidence against his co-accused Solito Tena. According to Section 28 of the Rules of Court, the rights of a party cannot be prejudiced by an act or declaration of another unless a conspiracy is proved. In this case, there was no evidence presented of a conspiracy between Camota and Tena. As the extrajudicial confession was the only evidence linking Tena to the crime, and it was deemed inadmissible, the court found Tena not guilty of robbery with homicide.
The Supreme Court of the Philippines ruled that the extrajudicial confession of Adelberto Camota was inadmissible as evidence against his co-accused Solito Tena. According to Section 28 of the Rules of Court, the rights of a party cannot be prejudiced by an act or declaration of another unless a conspiracy is proved. In this case, there was no evidence presented of a conspiracy between Camota and Tena. As the extrajudicial confession was the only evidence linking Tena to the crime, and it was deemed inadmissible, the court found Tena not guilty of robbery with homicide.
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G.R. No.
100909
October 21, 1992
PEOPLE OF THE PHIL. vs. SOLITO TENA
On June 19, 1988, 82-year-old Alfredo Altamarino, Sr. was found dead inside the bedroom of his house located at corner Gardner and Regidor Streets, Barangay Sadsaran, Mauban, Quezon. The deceased's bedroom was in a topsy-turvy state; his cabinet's drawers had been opened and ransacked. Suspicion fell on the deceased's caretakers, the spouses William Verzo and Ofelia Ritual, but investigation by the Mauban Police Force yielded no evidence to warrant the filing of charges against them. Emma Altamarino Ibana sought the help of the National Bureau of Investigation (NBI). NBI Agents arrived at Mauban, Quezon to conduct their own investigation. Mauban Police Station Commander Lt. Gironimo de Gala informed them that suspicion as to the authorship of the crime had shifted to a syndicate operating in Lucena City and nearby municipalities. This syndicate was reportedly involved in the robbery of a Petron Gas Station owned by a certain Benjamin Lim and a member thereof, Adelberto Camota, was then in detention. The NBI Agents interrogated Camota. When confronted, Adelberto Camota executed an extrajudicial confession in the presence of Atty. Albert Siquijor, admitting participation in the robbery-killing of Alfredo Altamirano, Sr. and pointing to Virgilio Conde, Jose de Jesus, Solito Tena and an unidentified person as his companions in the crime. An information for the crime of Robbery with Homicide was subsequently filed by the Assistant Provincial Fiscal against Virgilio Conde, Jose de Jesus Jr., Adelberto Camota, Solito Tena and John Doe. Virgilio Conde and Solito Tena pleaded not guilty upon arraignment on November 12, 1989 as did Adelberto Camota when arraigned on January 17, 1990. On February 26, 1991, the Trial Court rendered a decision finding accused Virgilio Conde, Adelberto Camota and Solito Tena are all found guilty beyond reasonable doubt of the complex crime of Robbery with Homicide. There was no eyewitness to the commission of the crime. The judgment of conviction was based chiefly on the extrajudicial confession of accused Adelberto Camota.
Issue: Whether or not the extrajudicial confession made by Camota is admissible in evidence against Tena.
Ruling: NO. The court ruled that the use of Camota's extrajudicial confession is precluded by Section 25 (now Section 28), of Rule 130 of the Rules of Court, viz:
Section 28. Admission by third party. The rights of a party cannot be
prejudiced by an act, declaration, or omission of another, except as hereinafter provided.
On a principle of good faith and mutual convenience, a man's own acts are binding upon himself, and are evidence against him. So are his conduct and declarations. Yet it would not only be rightly inconvenient, but also manifestly unjust, that a man should be bound by the acts of mere unauthorized strangers; and if a party ought not to be bound by the acts of strangers, neither ought their acts or conduct be used as evidence against him. But there is an exception, it is admissible in evidence if it is proved that a coconsprirator relationship exists between Camota and Tena. In order that the admission of a conspirator may be received against his co-conspirator, it is necessary that (a) the conspiracy be first proved by evidence other than the admission itself; (b) the admission relates to the common object; and (c) it has been made while the declarant was engaged in carrying out the conspiracy. There exists no evidence of conspiracy between Camota and accusedappellant Tena. As stressed by the trial court, there was no eyewitness to the commission of the crime and none of the circumstantial proofs considered by the court a quo points to a conspiracy between Camota and accused-appellant Tena. For another, the extrajudicial confession was executed only February 1, 1989, long after the supposed conspiracy between Camota and accused-appellant had come to an end. The extrajudicial confession of Camota thus being inadmissible against his coaccused, and there being no evidence independently of said confession, linking accused-appellant Solito Tena to the crime, this Court declares Tena not guilty of the complex crime of robbery with homicide with which he is charged.
G.R. No. 182356 December 4, 2013 DRA, LEILA A DELA LLANO, Petitioner, vs. REBECCA BIONG, Doing Business Under The Name and Style of Pongkay Trading, Respondent. D E C I S I O N
