[G.R. No.

1272 January 11, 1904]

THE UNITED STATES, complainant-appellee,

vs.
BALDOMERO NAVARRO, ET AL., defendants-appellants.

FACTS:

According to information, the defendants, Baldomero Navarro, Marcelo de

Leon, and Fidel Feliciano, are charged with the crime of illegal detention
under Articles 481 and 483 of the Penal Code. They are said to have entered
Felix Punsalan's home in Matang-tubig, Province of Bulacan, one night
around the middle of November 1902 with other unidentified individuals,
armed with revolvers and daggers, and kidnapped the said Felix Punsalan.

On appeal, the defendants' attorneys claimed that the law's provisions

effectively forced a defendant to testify in his own defense or face a
considerably harsher punishment. The weight of proof falls on him if he
wants to reduce the punishment, or, to put it another way, if he wants to
incriminate himself. After all, just stating the victim's whereabouts or
proving that the defendant released him amounts to a confession that the
defendant wrongfully detained the person. The counsel for the defendants
claimed that such practice is illegal, since section 5 of the Philippine Bill
provides that ". . . no person shall be compelled in any criminal case to be a
witness against himself."

ISSUE:
Whether or not the defendants' rights against self-incrimination were
violated.

HELD: 

Yes. The defendants’ rights against self-incrimination were violated.

Under the law, the right against self-incrimination was established on the
grounds of public policy and humanity because, if a party were required to
testify, the witness would be most likely to be persuaded to commit the
crime of perjury, and because it would prevent the coercion of confessions.

In this case, it is the prosecution's responsibility to convict a defendant of a

crime and to present evidence that proves guilt beyond a reasonable doubt;
the accused cannot be asked to contribute to the gathering of this evidence
through express words or deeds, and his silence should not be used as
evidence against him. Until the prosecution can establish that he is guilty of
every aspect of the crime for which he is charged, he has the right to
depend on the presumption of innocence.