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
Petitioner: PEOPLE OF THE PHILIPPINES
Respondent: RODERICK LICAYAN, ROBERTO LARA and ROGELIO “NOEL”
DELOS REYES
DOCTRINE
In criminal cases, except those involving quasi-offenses or those allowed by law to be
settled through mutual concessions, an offer of compromise by the accused may be
received in evidence as an implied admission of guilt. For this rule to apply, it is not
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
compromise and such offer is proved.
FACTS
1. Five-year old Rowena C. Bangcong, the only girl among her siblings, was
beaten, raped and killed. Her bruised and battered body which was flung into
a nipa swamp was discovered the following morning after a massive search.
2. The accused here is Aldrin Licayan who was accused by the RTC based on
circumstantial evidence which are the following:
-Accused drank rhum with Bernard Agcopra and also drank at Rowena
Bangcong’s house.
-Accused kissed and embraced Rowena, justifying it by saying that he
missed his daughter.
-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
hand of Rowena and was dragging her
-One group spotted Licaya 20 meters away. He ran toward the direction of
the rice field
-At about 4:00 o'clock of June 26th Licayan told Jun-jun Dahilan about the
body of Rowena who in turn told the searchers the location of the body of Rowena.
-With muddy pants, wet and without slippers accused emerged at the place
where Wilson Salvaña and companions were drinking
-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-
appellant's admission is hearsay. Also contends that it is a extrajudicial
confession that cannot be used against him.
ISSUE/S
1. W/N, the confession of Licayan to Jun can be used against him.
RULING & RATIO
YES
jun" Dahilan, Jr. as to the location of the victim's body is hearsay. Any oral or
documentary evidence is hearsay by nature if its probative value is not based on the
personal knowledge of the witnesses but on the knowledge of some other person who
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
hearsay.
- In the instant case, Rogelio Dahilan, Jr. testified that accused-appellant indeed told
him where the victim's body can be found. What is more, the victim's body was
actually recovered at the location pointed by accused-appellant.
-Accused-appellant's objection to the admissibility of his statement as to where he
dumped the body of the victim, which allegedly partakes of an extra-judicial
confession, is just as tenuous.
-The foregoing is not an extra-judicial confession, but merely an extra-judicial
admission because it was not before an officer. The records show that Rogelio "Jun-
jun" Dahilan was neither a law enforcement nor a public officer conducting a custodial
interrogation of accused-appellant. He was merely a jeepney driver and an
acquaintance of accused-appellant who asked the whereabouts of the missing child
of his kumpadre because the victim was last seen with the latter.
-Even assuming arguendo that accused-appellant's admissions indeed partake of an
extra-judicial confession, the same would still be admissible not only on account of
the foregoing considerations but also because it is corroborated by evidence of
corpus delicti.
-Under Rule 133, Section 3 of the Rules of Court, an extra-judicial confession
shall not be sufficient ground for conviction, unless corroborated by evidence
of corpus delicti, which is defined as the body of the crime and, in its primary
sense, means a crime has actually been committed. Applied to a particular
offense, it is the actual commission by someone of the particular crime charged. In
this case, aside from the admission made by accused-appellant, the bruised and
battered body of the victim herself recovered at the exact spot described by accused-
appellant conclusively established the corroborating evidence of corpus delicti.
DISPOSITION
-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
Marikina in Criminal Case No. 98-2605-MK and 98-2606-MK dated February 17,
2009, is hereby AFFIRMED
Page 1 of 1