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People v.

Licayan(Short title) - Accused-appellant cannot validly claim that the statement made by Rogelio "Jun-
G.R. No. 203961 | 378 SCRA 281 | July 29, 2015 jun" Dahilan, Jr. as to the location of the victim's body is hearsay. Any oral or
Petitioner: PEOPLE OF THE PHILIPPINES documentary evidence is hearsay by nature if its probative value is not based on the
Respondent: RODERICK LICAYAN, ROBERTO LARA and ROGELIO “NOEL” personal knowledge of the witnesses but on the knowledge of some other person who
DELOS REYES was never presented on the witness stand, because it is the opportunity to cross-
examine which negates the claim that the matters testified to by a witness are
DOCTRINE hearsay.

In criminal cases, except those involving quasi-offenses or those allowed by law to be - In the instant case, Rogelio Dahilan, Jr. testified that accused-appellant indeed told
settled through mutual concessions, an offer of compromise by the accused may be him where the victim's body can be found. What is more, the victim's body was
received in evidence as an implied admission of guilt. For this rule to apply, it is not actually recovered at the location pointed by accused-appellant.
necessary that a complaint be first filed by the victim because all that is required is
that after committing the crime, appellant or his representative makes an offer to -Accused-appellant's objection to the admissibility of his statement as to where he
compromise and such offer is proved. dumped the body of the victim, which allegedly partakes of an extra-judicial
confession, is just as tenuous.
FACTS
-The foregoing is not an extra-judicial confession, but merely an extra-judicial
1. Five-year old Rowena C. Bangcong, the only girl among her siblings, was admission because it was not before an officer. The records show that Rogelio "Jun-
beaten, raped and killed. Her bruised and battered body which was flung into jun" Dahilan was neither a law enforcement nor a public officer conducting a custodial
a nipa swamp was discovered the following morning after a massive search. interrogation of accused-appellant. He was merely a jeepney driver and an
acquaintance of accused-appellant who asked the whereabouts of the missing child
2. The accused here is Aldrin Licayan who was accused by the RTC based on of his kumpadre because the victim was last seen with the latter.
circumstantial evidence which are the following:
-Accused drank rhum with Bernard Agcopra and also drank at Rowena -Even assuming arguendo that accused-appellant's admissions indeed partake of an
Bangcong’s house. extra-judicial confession, the same would still be admissible not only on account of
-Accused kissed and embraced Rowena, justifying it by saying that he the foregoing considerations but also because it is corroborated by evidence of
missed his daughter. corpus delicti.
-Rey saw accused telling Rowena "Day come here because your father
asked you to go home so that you can eat your supper." Accused was holding the -Under Rule 133, Section 3 of the Rules of Court, an extra-judicial confession
hand of Rowena and was dragging her shall not be sufficient ground for conviction, unless corroborated by evidence
-One group spotted Licaya 20 meters away. He ran toward the direction of of corpus delicti, which is defined as the body of the crime and, in its primary
the rice field sense, means a crime has actually been committed. Applied to a particular
-At about 4:00 o'clock of June 26th Licayan told Jun-jun Dahilan about the offense, it is the actual commission by someone of the particular crime charged. In
body of Rowena who in turn told the searchers the location of the body of Rowena. this case, aside from the admission made by accused-appellant, the bruised and
-With muddy pants, wet and without slippers accused emerged at the place battered body of the victim herself recovered at the exact spot described by accused-
where Wilson Salvaña and companions were drinking appellant conclusively established the corroborating evidence of corpus delicti.
-Accused was the last person with whom Rowena was last seen

3. Licayan contends that the claim of prosecution witnesses that Jun-jun Dahilan
told them where Rowena's body could be found based on accused- DISPOSITION
appellant's admission is hearsay. Also contends that it is a extrajudicial
confession that cannot be used against him. -WHEREFORE, the Decision of the Court of Appeals in CA-G.R. CR-H.C. No. 03797
dated July 4, 2012, which affirmed in toto the disposition of the Regional Trial Court of
ISSUE/S Marikina in Criminal Case No. 98-2605-MK and 98-2606-MK dated February 17,
2009, is hereby AFFIRMED
1. W/N, the confession of Licayan to Jun can be used against him.

RULING & RATIO

YES

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