People of the Philippines vs. Suarez, et. al.

G.R. No. 111193
January 28, 1997

REGALADO, J.:

Facts:

On or about the 8th day of December, 1987 in the Municipality of Pasig, Estrelita Guzman was robbed and was killed in her own house.

Suarez wanted his aunt killed so that he and his wife, Marivic Suarez, also the victim’s adopted daughter, could get at once any property that Marivic might inherit from Estrellita upon the latter's death. In exchange for the job, Suarez would allow the other accused to steal what they wanted from the house, in addition to giving them P100,000.00 after one month from the killing of Estrellita.

Two of the accused, Reyes and Lara, gave their sworn statement detailing what transpired from the planning until the execution of the crime.

Relying on the extrajudicial confessions of the accused and on the circumstantial evidence adduced by the prosecution, the trial court found Suarez, Reyes and Lara guilty beyond reasonable doubt of robbery with homicide.

Issue: 

Whether the extrajudicial confessions of each of the accused are binding against each other and admissible in evidence

Ruling:

YES. If it is made freely and voluntarily, a confession constitutes evidence of a high order since it is supported by the strong presumption that no sane person or one of a normal mind will deliberately and knowingly confess himself to be the perpetrator of a crime unless prompted by truth and
conscience.

Extrajudicial confessions independently made without collusion, almost identical with each other in their essential details which could have been known only to the declarants, and corroborated by other evidence against the person or persons implicated to show the probability of the latter's actual participation in the commission of the crime, are thus impressed with features of voluntariness in their execution

The court treated the confessions of the three accused as interlocking confessions sufficient to corroborate and bolster the truth of each accused's own incriminating statements. This doctrine of interlocking confessions has been accepted and recognized in numerous decisions of this Court as an exception to the res inter alios acta rule and the hearsay rule. Reyes' confession is thus admissible against Lara to show the probable involvement of the latter in the perpetration of the crime. Where the confession is used as circumstantial evidence to show the probability of participation by an accused co-conspirator, that confession is receivable as evidence against him.