People vs. Janjalani CASE DIGEST EVIDENCE - JUDICIAL ADMISSIONS, G.R. No. 188314, January 10, 2011

 People vs. Janjalani, G.R. No. 188314, January 10, 2011

P: Sereno

 

FACTS: Baharan and Trinidad boarded the RRCG bus. According to the bus conductor, he immediately became wary of the two men, because, even if they got on the bus together, the two sat away from each other – one behind the driver, the other at the back of the bus. Moments after they alighted the bus, Andales felt an explosion and saw the bus on fire.  As stipulated during pretrial, Trinidad and Baharan gave an interview confessing their participation in the bombing incident. Members of the Abu Sayyaf Group, Janjalani et al were then charged with multiple murder and multiple frustrated murder. Only Baharan, Trinidad, Asali, and Rohmat were arrested

During pretrial, Baharan, Trinidad, and Asali all admitted to causing the bomb explosion which left 4 people dead and more or less 40 persons injured. Baharan and Trinidad agreed that they gave interviews admitting their participation. They all admitted that they are members of the Abu Sayyaf.

RTC convicted the 3 of the complex crime of multiple murder and multiple frustrated murder, and sentenced them to suffer the penalty of death by lethal injection. CA modified the sentence to reclusion perpetua.

ISSUE: Whether or not the extrajudicial confession of Asali is inadmissible as evidence.

HELD: No. Asali’s clear and categorical testimony, which remains unrebutted on its major points, coupled with the judicial admissions freely and voluntarily given by the 2 other accused, are sufficient to prove the existence of a conspiracy hatched between and among the 4 accused.

In People v. Buntag, if the declarant repeats the statement in court, his extrajudicial confession becomes a judicial admission, making the testimony admissible as to both conspirators. In People v. Palijon, an extrajudicial confession may be given in evidence against the confessant but not against his co-accused as they are deprived of the opportunity to cross-examine him. A judicial confession is admissible against the declarant’s co-accused since the latter are afforded opportunity to cross-examine the former. Sec. 30, Rule 130 of the Rules of Court applies only to extrajudicial acts or admissions and not to testimony at trial where the party adversely affected has the opportunity to cross-examine the declarant. CA is affirmed.