INTERLOCKING CONFESSION

The Supreme Court ruled the appellant Reyes’s claim that the extra-judicial confessions of
his co-appellants Arnaldo and Flores cannot be used in evidence against him is incorrect as
although an extra-judicial confession is admissible only against the confessant,
jurisprudence makes it admissible as corroborative evidence of other facts that tend to
establish the guilt of his co-accused (Santos v. Sandiganbayan, 400 Phil. 1175, 1206
{2000}). In People v. Alvarez, G.R. No. 88451, 5 September 1991, 201 SCRA 364, 37, the
Supreme Court ruled that where the confession is used as circumstantial evidence to show
the probability of participation by the co-conspirator, that confession is receivable as evidence
against a co-accused.
In People v. Encipido, 230 Phil. 560, 574 (1986), the Supreme Court also elucidated as
follows: “It is also to be noted that APPELLANTS’ extrajudicial confessions were
independently made without collusion, are identical with each other in their material respects
and confirmatory of the other. They are, therefore, also admissible as circumstantial
evidence against their co-accused implicated therein to show the probability of the latter’s
actual participation in the commission of the crime. They are also admissible as corroborative
evidence against the others, it being clear from other facts and circumstances presented that
persons other than the declarants themselves participated in the commission of the crime
charged and proved. They are what is commonly known as interlocking
confession and constitute an exception to the general rule that extrajudicial
confessions/admissions are admissible in evidence only against the declarants thereof”.
Ergo, appellants Arnaldo and Flores’ respective confessions that appellant Reyes
participated in their kidnapping of the Yao family are, therefore, admissible as corroborative
and circumstantial evidence to prove appellant Reyes’ guilt (PEOPLE vs. REYES [2009]).