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Legal Case Analysis: Evidence Admissibility

This document discusses several Supreme Court cases: - People v. Cachuela discusses the extrajudicial confession of Melvin Nabilgas implicating appellants Cachuela and Ibañez in robbery and homicide. The court ruled the confession inadmissible, as it was not made with legal counsel and is considered hearsay against co-accused. - Additional cases discussed include People v. Roa, People v. Omilig y Mancia, Mclaughlin v. Court of Appeals, Lazaro v. Agustin, DBP Pool of Accredited Insurance Co. v. Radio Mindanao Network, Inc., Land Bank of the Phils. v. Monet's Export and

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Julrey Garcia
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122 views2 pages

Legal Case Analysis: Evidence Admissibility

This document discusses several Supreme Court cases: - People v. Cachuela discusses the extrajudicial confession of Melvin Nabilgas implicating appellants Cachuela and Ibañez in robbery and homicide. The court ruled the confession inadmissible, as it was not made with legal counsel and is considered hearsay against co-accused. - Additional cases discussed include People v. Roa, People v. Omilig y Mancia, Mclaughlin v. Court of Appeals, Lazaro v. Agustin, DBP Pool of Accredited Insurance Co. v. Radio Mindanao Network, Inc., Land Bank of the Phils. v. Monet's Export and

Uploaded by

Julrey Garcia
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd

People v. Cachuela, G.R. No.

191752, June 10, 2013


People v. Roa, G.R. Nos. 138195-96, July 10, 2003
People v. Omilig y Mancia, G.R. No. 206296, August 12, 2015
Mclaughlin v. Court of Appeals, G.R. No. L-57552, October 10, 1986
Lazaro v. Agustin, G.R. No. 152364, April 15, 2010
DBP Pool of Accredited Insurance Co. v. Radio Mindanao Network, Inc., G.R. No. 147039,
January 27, 2006
Land Bank of the Phils. v. Monet's Export and Manufacturing Corp., G.R. No. 184971, April 19,
2010
Ambray, et al., v. Tsourous, et al., G.R. No. 209264, July 5, 2016

Respondent G.P. Sarmiento trucking company (GTS)


undertook to transport 30 unit

July 23, 2004 Ibañez went to Weapons System Corporation (WSC) on board an old car, and told Henessy Auron,
WSC’s Secretary and Sales Representative, that he was the one who bought a gun barrel at the company’s gun
show in SM Megamall. He also asked the days when there are many people in the 5ring range, and
whether Henessy was WSC's only female employee

At around 9:00 a.m. of July 26, 2004, Henessy arrived at WSC and rang the doorbell, but no one opened the door.
She went to the back of the office where the firing range was located, and called Zaldy Gabao, another employee of
WSC. Zaldy answered from inside the store and
replied that he could not open the door because his hands were tied.
After one hour, the police arrived. When Henessy and the police entered the premises, they saw that Zaldy had been
handcuffed to the vault. The police also entered the firing range, and saw the lifeless body of Rex.

The NBI decided to hold an entrapment operation after they received an information from an asset that the
group of Cachuela was involved in the said crime. During this entrapment, a certain Melvin Nabilgas told them
that he was sent by Cachuela and Ibañez to look for buyers of firearms. He surrendered to the police and
gave the names of the other persons involved in the crime.

Thereafter, NBI was able to arrest both Cachuela and Ibañez.

At the NBI Main Office, Zaldy pointed to the appellants, during a police line-up, as the persons responsible for the
robbery at WSC and for the killing of Rex. Nabilgas also executed a handwritten confession implicating the appellants
and Zaldy in the crime.

The prosecution filed an Information for robbery with homicide.

Issue: Whether Nabilgas’ extrajudicial admission is admissible against Cachuela and Ibañez

Ruling: No. Nabilgas' extrajudicial confession is inadmissible in evidence as it was not made with the
assistance of a competent and independent counsel.
And at any rate, Nabilgas' extrajudicial confession is inadmissible in evidence against the appellants in
view of the res inter alios acta rule. An extrajudicial confession is binding only on the confessant and is
not admissible against his or her co-accused because it is considered as hearsay against them.
The exception to this also does not apply in the present case since there was no other piece of
evidence presented, aside from the extrajudicial confession, to prove that Nabilgas conspired with the
appellants in committing the crime charged.

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