People V Yatco

Facts: Consunji, Panganiban, and John Doe were charged with having conspired together in the murder
of Ramos.

Counsel for the defendant Panganiban interposed a general objection to any evidence on such
confession made by Consunji on the ground that it was hearsay and therefore incompetent as against
the other accused Panganiban.

RTC ordered exclusion of the objected evidence on a different ground – prosecution should not be
permitted to introduce confessions of Consunji and Panganiban to prove conspiracy between them
without proof of such conspiracy.

Issue: WON RTC is correct in exlcusing the prosecution’s evidence

Ruling: No. Even Consunji’s confession may not be competent s against his co-accused Panganiban,
being hearsay, or to prove conspiracy between them without the conspiracy being established by other
evidence, the confession was admissible as evidence of the defendant’s own guilt and should be
admitted.