Rodillas vs Sandiganbayan

161 SCRA 347

Facts: Alfredo Rodillas y Bondoc was found guilty for the crime of infidelity in the
custody of Prisoner through negligence (Art 224, RPC). As a policeman, he was
charged with the duty of escorting a prisoner from the City jail to the CFI on March 27,
1980. By allowing the prisoner to dine with the family and go to the bathroom without
checking the premises, he enabled the prisoner to escape from his custody with great
carelessness and unjustifiable negligence. Petitioner alleged that his conviction by the
Sandiganbayan was based merely on his admissions without the prosecution
presenting evidence to prove his negligence.

Issue: W/N Rodillas is guilty of the crime of infidelity in the Custody of Prisoner through
negligence under Art 224

Held: Yes, Sec 22, Rule 130 of the Rules of Court provides that “the act, declaration, or
omission of a party as to a relevant fact may be given in evidence against him. The
admissions and declarations in open court of a person charged with a crime are
admissible against him. “The elements of the crime under Art. 224 are (a) the offender
is a public officer; (b) he is charged with conveyance or custody of a prisoner; and (c)
such prisoner escapes through his negligence.