University of the Philippines College of Law

Topic Res Inter Alios Acta

Case No. G.R. No. 119005
Case Name People v. Raquel
Ponente Regalado
Digester Rojo, Aliyah

Quick Facts
Cause of Action Appeal from an RTC decision
(Complaint/ Information)
Evidence in Question Extrajudicial statement of Amado Ponce
pointing to accused as co-perpetrators of crime
How was it raised to the SC? Appeal
Trial Court Decision Guilty of robbery w/ homicide
Supreme Court Decisions Acquit (except Amado Ponce who is still at
large)

SUMMARY

RELEVANT FACTS
 At midnight, accused knocked on door of the house of the Spouses Gambalan. Agapita
Gambalan opened the door and heavily armed men emerged, declared hold-up, and fired their
guns at him.
o Juliet Gambalan went out of their room after hearing gunshots and saw her husbands’
lifeless body while a man took her husbands gun and left.
o Juliet also saw a man fall beside their water pump while two other men raw away.
 Accused Sabas Raquel, Valeriano Raquel and Amado Ponce were indicted for robbery w/
homicide in RTC.
o All pleaded not guilty in arraignment
 While trial was in progress and before he could give a testimony, accused Amado Ponce
escaped from jail.
o TC found all accused guilty
ISSUE/S
 W/N TC erred in convicting accused Sabas Raquel and Valeriano Raquel of crime charged
despite absence of evidence positively implicating them as perpetrators of crime? YES

RATIO DECIDENDI

Issue Ratio
W/N TC erred in YES
convicting accused
Raquels of crime charged 1. Prosec failed to establish beyond reasonable doubt the real identities
 University of the Philippines College of Law

despite absence of of the perpetrators of, much less participation of herein appellants,
evidence positively in crime charged.
implicating them as 2. Identification of the appellants as culprits was based chiefly on the
perpetrators of crime? extrajudicial statement of accused Amado Ponce pointing to them as
his co-perpetrators of the crime. Ponce escaped from jail before her
could testify and has been at large since then.
3. The extrajudicial statements of an accused implicating a co-
accused may not be utilized against the latter, unless these are
repeated in open court.
a. If the accused never had the opportunity to cross-examine his
co-accused on the latters extrajudicial statements, it is
elementary that the same are hearsay as against said accused.
b. A distinction, obviously, should be made between
extrajudicial and judicial confessions. The former deprives
the other accused of the opportunity to cross-examine the
confessant, while in the latter his confession is thrown wide
open for cross-examination and rebuttal
4. Res inter alios rule ordains that the rights of a party cannot be
prejudiced by an act, declaration, or omission of another.
a. An extrajudicial confession is binding only upon the
confessant and is not admissible against his co-accused.
b. Since 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.
5. Although rule has exceptions, such do not apply to present case.
a. There exists no evidence linking appellants to the crime.
b. Extrajudicial statement was made in violation of the
constitutional rights of accused (admitted in testimony of
officer)
6. Without the positive identification of appellants, the evidence of the
prosecution is not sufficient to overcome the presumption of
innocence guaranteed by the Bill of Rights to them.

RULING

WHEREFORE, on reasonable doubt, the appealed judgment is REVERSED and accused-appellants

Sabas Raquel and Valeriano Raquel are hereby ACQUITTED of the offense charged, with costs de
oficio.