People vs Bacus - The fact therefore that the trial court chose to give credence to these confessions as against

GR NO. 60388 the confessants [the three (3) other accused in this case] is irrelevant and immaterial to
Nov. 21, 1991 accused-appellant Arguelles’ cause as "it is a basic rule of evidence that the right of a party
By: Pax cannot be prejudiced by an act, declaration or omission of another," and this is embodied in
the legal maxim "res inter alias acta alteri noceri non debet."
Topic: Burden of Proof and Presumptions
Petitioners: People EXTRA RULING REGARDING SUFFICIENCY OF EVIDENCE:
Respondents: Bertito Bacus, Arnold Arguelles, etc. - Courts should generally exercise great care and vigilance to insure that a verdict of
conviction is supported by sufficient and competent evidence and not the result of passion
FACTS: and prejudice for it is fundamental that the prosecution, to secure conviction for any crime,
- Accused Bertito Bacus, Antonio Poleran, Abuncio Sumalpong, and Arnold Arguelles were all must rely on the strength of its own evidence and not on the weakness of the defense, as its
found guilty of murder by the RTC for the death of Vicente Sumalpong, a septuagenarian. duty is in demonstrating where culpability lies.
- This case follows the appeal only of accused Arnold Arguelles. The others accepted the RTC
conviction.
- Out of the 4 accused, Arguelles was the last one to be caught by the police. It took 7 years
after the crime for him to be captured. He pleaded not guilty.
- His main defense is alibi. He claims that prior to the date of the crime and during, he was
nowhere near the scene of the crime as he was in Pagadian City working in his flower shop
which was 12 hrs away from Dipolog City (Crime Scene)
- Arguelles also argued that the prosecution witnesses Lieutenant Gonzales and Carmelita
Orpiala had grudges against him and as a result, implicated him to the crime.
- RTC convicted him of murder as the same with the other accused. The extrajudicial
confessions of co-accused Bertito Bacus, Antonio Poleran and Abuncio Sumalpong were
considered as evidence against Arguelles.
- Arguelles appealed arguing that the extrajudicial confessions are hearsay and that three (3)
other accused retracted said confessions in court. Arguelles also stated that the confessions
were involuntary for having been obtained through maltreatment, intimidation and promise
of reward or leniency.
- Arguelles thus submits that the extrajudicial confessions of the three (3) other accused
should be deemed inadmissible against him for the settled rule on the matter is that
"extrajudicial statements of an accused implicating a co-accused may not be utilized against
the latter unless repeated in open court."

ISSUE:
W/N Arguelles’ conviction is proper.

HELD/RATIO: NO
- The conviction of accused-appellant Arnold Arguelles by the trial court was grounded on the
admission as competent evidence of the extrajudicial confessions of the three (3) other
accused.
- These confessions allegedly point to accused-appellant’s presence as well as direct
participation in the murder of Vicente Sumalpong.
- These confessions should, however, have been deemed inadmissible against accused-
appellant Arguelles for said confessions are hearsay as against him. Moreover, these
confessions were recanted and repudiated by their authors for alleged maltreatment and/or
promise of regard or leniency.
- Besides, Accused-appellant Arguelles never had the chance to cross-examine the affiants in
regard to the contents of their confessions insofar as they implicated him.