People v Encipido

Facts: Jose Lacumbas was found dead by his wife and children. Petitioners were charged with murder.
The prosecution’s witness, Alciso testified that he saw petitioners were the ones who killed the
deceased. Later on, on of the co-accused (de la Pena) testified that he was forced to join the group to kill
the deceased.

RTC found appellants guilty

Issue: WON the judicial admission by the accused de la Pena against his co-accused is admissible.

Ruling: Yes. The appellants’ extra-judicial 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, and also admissible as corroborative
evidence against others, it being declarants themselves participated in the commission of the crime
charged and proved.