PEOPLE Vs Gaddi Digest

People v.
Gaddi
Rule 130 Section 22. Testimony confined to personal knowledge. – A witness can testify only to those facts which
he or she knows of his or her personal knowledge; that is, which are derived from his or her own perception. (36a)
Facts:
Nerio Gaddi y Catubay was charged with murder for the death of one Augusto Esguerra y Navarro. The two were
drinking at the back of the house of Ernesto Guzman. Guzman alleged that Gaddi confessed that he stabbed
Navarro. On trial Gaddi claimed that Guzman’s testimony on his confession cannot be given credence for being
hearsay.
Issue:
Whether the testimony of Ernesto Guzman is hearsay and cannot be given credence.
Ruling:
No.
Moreover, appellant's claim that Ernesto Guzman's testimony on Gaddi's confession of the crime to him cannot be
given credence for being hearsay is unavailing. This Tribunal had previously declared that a confession constitutes
evidence of high order since it is supported by the strong presumption that no person of normal mind would
deliberately and knowingly confess to a crime unless prompted by truth and his conscience [People v. Salvador,
G.R. No. L-77964, July 26, 1988 citing People v. Castaneda; G.R. No. L-32625, August 31, 1979, 93 SCRA 59.]
Proof that a person confessed to the commission of a crime can be presented in evidence without violating the
hearsay rule [Section 30, Rule 130 of the Revised Rules of Court] which only prohibits a witness from testifying as
to those facts which he merely learned from other persons but not as to those facts which he "knows of his own
knowledge; that is, which are derived from his own perception ." Hence, while the testimony of a witness
regarding the statement made by another person, if intended to establish the truth of the fact asserted in the
statement, is clearly hearsay evidence, it is otherwise if the purpose of placing the statement in the record is
merely to establish the fact that the statement was made or the tenor of such statement [People v. Cusi, Jr., G.R.
No. L- 20986, August 14, 1965, 14 SCRA 944.] Here, when Guzman testi􀁌ed that the appellant, who probably was
bothered by his conscience, admitted the killing to him, there was no violation of the hearsay rule as Guzman was
testifying to a fact which he knows of his own personal knowledge; that is, he was testifying to the fact that the
appellant told him that he stabbed Augusto Esguerra and not to the truth of the appellant's statement. Doctrine of
independent relevant statement.
That the testimony of Guzman on appellant's oral confession is competent evidence 􀁌nds support in People v.
Tawat [G.R. No. L-62871, May 25, 1984, 129 SCRA 431] which upheld the trial court's reliance on an extrajudicial
confession given, not to a police o􀁍cer during custodial interrogation, but to an ordinary farmer as the basis for
conviction.
The Court's pronouncements in the aforesaid case 􀁌nd relevance in the instant case:
"The declaration of an accused expressly acknowledging his guilt of the offense charged, may be given in
evidence against him" (Sec. 29 Rule 130, Rules of Court). What Felicito told Ogalesco may in a sense be also
regarded as part of the res gestae.
The Rule is that "any person, otherwise competent as a witness, who heard the confession, is competent to
testify as to the substance of what he heard if he heard and understood all of it. An oral confession need not
be repeated verbatim, but in such a case it must be given in its substance." (23 C.J.S. 196.)
"Proof of the contents of an oral extrajudicial confession may be made by the testimony of a person who
testifies that he was present, heard, understood, and remembers the substance of the conversation or
statement made by the accused" [citing Underhill's Criminal Evidence, 4th Ed., Niblack, Sec. 278, p. 551] [at
pp. 436- 437; Emphasis supplied.]
The trial court found no reason to doubt Guzman's credibility as a witness considering his stature in the
community as a member of a religious movement participating in such activities as "mañanita" and procession of
the Fatima and Black Rosary [Rollo, p. 30.] In fact, on the day the killing took place, he left his house where
appellant and his companion, Esguerra, were still drinking and went to the house of Junior Isla to attend a
"mañanita" and participate in the weekly activity of bringing down the cruci􀁌x and the image of the Fatima [TSN,
September 2, 1982. p. 2] Besides, there was no showing at all that he was actuated by improper motives in
testifying against appellant so as to warrant disregard of his testimony [People v. Magdueno, G.R. No. L- 68699,
September 22, 1986, 144 SCRA 210.] On the contrary, the evidence shows that even though the appellant is not
related at all to Guzman, the latter, as an act of generosity, allowed the former to sleep in the porch of his house as
the former had no immediate relatives in Quezon City [TSN, August 9, 1983, p. 14.]
As to the testimony of Pat. Angeles and Pat. Castillo, the police o􀁍cers who apprehended the appellant, credence
should be given to their narration of how the appellant was apprehender and how he led the police and the
barangay residents to the place where he dumped the body of his victim since those police o􀁍cers are presumed to
have performed their duties in a regular manner in the absence of evidence to the contrary.
ALIBI, INHERENTLY A WEAK DEFENSE, REQUIRED TEST TO OVERCOME EVIDENCE OF THE PROSECUTION. — It has
been ruled time and again that courts look upon the evidence of alibi with suspicion and always receive it with
caution not only because it is inherently weak and unreliable but also because of its easy fabrication. To overcome
the evidence of the prosecution, an alibi must satisfy the test of "full, clear and satisfactory evidence" This test
requires not only proof that the accused was somewhere else other than the scene of the crime but clear and
convincing proof of physical impossibility for the accused to have been at the place of the commission of the crime.
The testimony of the accused himself believes any claim of physical impossibility for him to be at the scene of the
crime since according to him, the store where he allegedly bought another bottle of gin was only 200 meters away.
He was able to return to Guzman's house only after half an hour since he still had a chat with an acquaintance at
the store. Even granting the truth of appellant's story that he was ordered by Guzman to buy a bottle of gin at
about 5:00 o'clock in the afternoon and that he was back after thirty minutes, it was not impossible for him to have
committed the crime since Guzman and his wife left appellant alone with the victim at around 6:00 o'clock in the
evening to attend the mañanita at the house of Junior Isla. Thus, his statements on the witness stand, far from
demonstrating physical impossibility of being at the scene of the crime, cast serious doubt on the veracity of his
alibi.

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