25. United States v. Navarro, et al.
trial court found the 3 accused guilty and meted out the
G.R. No. 1272 January 11, 1904
TOPIC: Right Against Self-Incrimination
Summary:
This case is an appeal of the decision of the lower court
finding the accused Navarro et al. They allege that they cannot
be convicted under Art 483 because it violates their guaranteed
rights by act of Congress on July 1, 1902. The SC finds merit
in this allegation saying that the law cannot force the accused
to testify against himself and such act is not in accordance with
the existing policy of the land. Thus, the accused were
convicted under Art 482 of the Penal Code with the
aggravating circumstance of nocturnity and they are sentenced
to suffer reclusion temporal.
Doctrine:
The right against self-incrimination was established on
the grounds of public policy and humanity — of policy,
because if the party were required to testify, it would place the
witness under the strongest temptation to commit the crime of
perjury, and of humanity, because it would prevent the
extorting of confessions by duress.
Facts:
The 3 accused were charged with kidnapping Felix
Punsalan without giving any information about him nor did
they provide any evidence to show that they already set him
free. During the trial the prosecution presented 3 witnesses.
Along with these witnesses one of the defendants, Marcelo De
Leon, took the witness stand and claimed that his other 2 co-
accused did kidnap Punsalan and that his knowledge about the
matter was brought by him being one of the kidnappers. The
punishment of Life Imprisonment in accordance with Art 483
of the Penal Code.
Relevant Issue:
Whether or not the law can compel the accused to
witness against himself for fear of harsher punishment?
Ruling: NO
Ratio:
The right against self-incrimination was established on
the grounds of public policy and humanity — of policy,
because if the party were required to testify, it would place the
witness under the strongest temptation to commit the crime of
perjury, and of humanity, because it would prevent the
extorting of confessions by duress.
It had its origin in a protest against the inquisitorial
methods of interrogating the accused person, which had long
obtained in the continental system.
In other words, the very object of adopting this
provision of law was to wipe out such practices as formerly
prevailed in the Philippines under the Spanish rule that requires
the accused to submit to judicial examinations, and to get
testimony regarding the offense with which they were charged
or if they refuse face stricter punishment.
It must be remembered that It is the prosecution that has
a duty, in order to convict one of a crime, to produce evidence
showing guilt beyond a reasonable doubt; and the accused
cannot be called upon either by express words or acts to assist
in the production of such evidence; nor should his silence be
taken as proof against him. He has a right to rely on the
presumption of innocence until the prosecution proves him
guilty of every element of the crime with which he is charged.