People vs. Yatco, etc., et al. SEC. 14. Confession.
— The declaration of an accused expressly
Digest Author: FABI
DOCTRINE:
OBJECTIONS, WAIVER OF; COURT HAS No POWER TO DIS-REGARD
EVIDENCE "MOTU PROPRIO."—
The exclusion of the proffered confessions was not made on the
basis of the objection interposed by defense counsel, but upon an
altogether different ground, which the Court issued motu proprio.
By so doing, the Court overlooked that the right to object is a mere
privilege which the parties may waive; and if the ground for
objection is known and not seasonably made, the objection is
deemed waived and the Court has no power, on its own motion, to
disregard the evidence
FACTS:
1. Consunji, Panganiban, and John Doe were charged with having
conspired together in the murder of Ramos.
2. During the trial, counsel for the defendant Panganiban interposed a
general objection to any evidence on such confession made by
defendant Consunji on the ground that it was hearsay and therefore
incompetent as against the other accused Panganiban.
3. The trial court ordered the exclusion of the objected evidence but on a
different ground which is “the prosecution could not be permitted to
introduce the confessions of defendants Consunji and Panganiban to
prove conspiracy between them, without prior proof of such conspiracy
by a number of definite acts, conditions, and circumstances”.
4. OSG filed a petition for certiorari before the SC for the review and
annulment of the Trial Court's order completely excluding any evidence
on the extrajudicial confessions of the accused Consunji and Alfonso.
ISSUE: W/N the trial court is correct in excluding the prosecutions’s
evidence (extra-judicial confession by Consunji)?
RULING+RATIO: NO
LB: Section 14, Rule 123, Rules of Court, is specific as to the admissibility of
the extrajudicial confession of an accused, freely and voluntarily made, as
evidence against him.
acknowledging the truth of his guilt as to the offense charged, may be given
in evidence against him.
AP: In this case, even if Consunji's confession may not be competent as
against his co-accused Panganiban, being hearsay, or to prove conspiracy
between them without the conspiracy being established by other evidence,
the confession of Consunji was, nevertheless, admissible as evidence of the
declarant's own guilt and should be admitted.
Issue: W/N the court has the power to disregard evidence on its
own if the objection is waived by the parties?
The court has no power to disregard evidence motu proprio.
LB: The right to object is a mere privilege which the parties may waive; and
if the ground for objection is known and not reasonably made, the objection
is deemed waived and the Court has no power, on its own motion, to
disregard the evidence.
AP: In this case, the exclusion of the proferred confessions was not made
on the basis of the objection interposed by Panganiban's counsel, but upon
a different ground, which the Court issued motu proprio.
Panganiban's counsel objected to Consunji's confession as evidence of the
guilt of the other accused Panganiban, on the ground that it was hearsay.
But the Court, instead of ruling on this objection, put up its own
objection to the confessions — that it could not be admitted to prove
conspiracy between Consunji and Panganiban without prior
evidence of such conspiracy and completely excluded the confessions on
that ground.
Therefore, the Trial Court overlooked that the right to object is a mere
privilege which the parties may waive; and if the ground for objection is
known and not reasonably made, the objection is deemed waived and the
Court has no power, on its own motion, to disregard the evidence.
DISPOSITION: petition is dismissed
1
Sec. 5.Substantial evidence.

1. In cases filed before administrative or

quasi-judicial bodies,

2. a fact may be deemed established if it is

supported by substantial evidence, or

3. that amount of relevant evidence which a

reasonable mind might accept as adequate
to justify a conclusion.

Sec. 6. Power of the court to stop further

evidence

The court may stop further testimony upon any

particular point when the evidence upon it is
already full that more with witnesses to the
same point cannot be reasonably expected to be
additionally persuasive.

This power should be exercised with caution