PEOPLE v.

MAQUI
March 14, 1914 | GR No. L-8931| Carson, J. | Admissions and Confessions - Compromises

PLAINTIFF-APPELLEE: The United States

DEFENDANT-APPELLANT: Juan Maqui
SUMMARY: Maqui was convicted of theft of a female carabao. In his appeal, his counsel contends that Maqui's
extrajudicial statements to compromise during the pendency of the case should be excluded on the ground that there
was no proof on record that they were made voluntarily. SC ruled that the record clearly discloses that Maqui offered to
compromise voluntarily, hoping that if accepted, he would escape prosecution.

DOCTRINE: Evidence of offers to compromise are admitted. | An offer of compromise, voluntarily made by the
accused, without threat or promise, and the reply thereto, are admissible in evidence upon his trial for a crime.

FACTS:
1. Defendant Maqui was convicted in the trial court of theft of
a caraballa (female carabao) and her calf. He was sentenced to
imprisonment for 5 years, to pay accessory penalties and to
pay his share for the costs of the proceedings. Hence this
appeal.
2. Maqui's counsel contends that the extrajudicial statements
made by Maqui should be excluded on the ground that there is
no formal proof on the record that they were made voluntarily,
and are therefore inadmissible as proof insofar as they can be
construed as a confession of guilt.
ISSUE: WON the trial court erred in admitting certain
extrajudicial admissions alleged to have been made by Maqui,
including an offer to compromise the case by payment of a
sum of money? NO.
RULING: JUDGMENT AFFIRMED. Costs against apellant.
RATIO:
1. SC ruled that there was NO suggestion in the trial court's
record to indicate that these extrajudicial statements by Maqui
were NOT made volunatarily.
2. As long as the evidence as to the circumstances under
which the said incriminating statements were made to be
accepted as true, it clearly rebuts the possibility that they were
made involuntarily or were extorted. In this case, the record
clearly discloses that Maqui's extrajudicial statements were
made in the course of his offer to compromise and that they
were voluntarily made by Maqui in the hope that if accepted,
he would escape prosecution.
3. RULE: Evidence of offers to compromise are admitted.
But the accused is allowed to show that such offers
were not made under a guilty conscience, but merely
to avoid the inconvenience of imprisonment or
another reason which would justify the accused's
claim that the offer to compromise was not an
admission of guilt, but an attempt to avoid the legal
consequences which would ordinarily ensue
therefrom.
4. US v. Hunter: If the accused, under a guilty conscience,
repays/satisfies the original owner of the goods he stole, this is
admissible as evidence. But if the accused did this merely to
avoid the convenience of imprisonment and not under a
consciousness of guilt, it is not evidence.
Comparing this to our current case:
Since Maqui made the extrajudicial statements
voluntarily, then his statements can be admitted.
5. State v. Bruce: An offer of compromise, voluntarily made
by the accused, without threat or promise, and the reply
thereto, are admissible in evidence upon his trial for a crime.
6. State v. Rodriguez: An offer of compromise of a crime,
unaccepted by the prosecutor, may be proven by the State as
an admission of guilt, or as disclosing possession of the
property which is the subject of the burglary and larceny
challenged in the indictment.
7. [Not relevant but just in case pansinin ni Sir haha] Justice
Carson was kind of racist in this case. Although he applied the
"mitigating circumstance" of "lack of manifest instruction and
education" to Maqui, he based it on the fact that even if he's
not a member of "an uncivilized tribe of Igorots", Maqui is
still a densely ignorant and untutored fellow. (So he's saying
that the "uncivilized tribe of Igorots" is the benchmark of
being ignorant -__- Basta ganun yung dating haha, like the
tribal people of the Philippines are uncivilized/ignorant. White
Man's Burden ang peg hahahuhu)
Justice Carson goes on to say that there should be no
presumption arising from racial affiliation, but I think he
contradicted himself in that statement.
Hence, the penalty applicable to Maqui is that of
presidio correccional in its medium degree.
(Applying the mitigating circumstance of lack of
manifest instruction and education)
Penalty is modified to 2 years, 4 months and 1 day of
presidio correccional.