25. United States v. Navarro, et al.
found the 3 accused guilty and meted out the punishment of Life
G.R. No. 1272 January 11, 1904
TOPIC: Right Against Self-Incrimination
Summary:
This case is an appeal of the decision of the lower court
finding the accused Navarro et al. They allege that they cannot
be convicted under Art 483 because it violates their guaranteed
rights by act of Congress on July 1, 1902. The SC finds merit in
this allegation saying that the law cannot force the accused to
testify against himself and such act is not in accordance with the
existing policy of the land. Thus, the accused were convicted
under Art 482 of the Penal Code with the aggravating
circumstance of nocturnity and they are sentenced to suffer
reclusion temporal.
Doctrine:
The right against self-incrimination was established on
the grounds of public policy and humanity — of policy, because
if the party were required to testify, it would place the witness
under the strongest temptation to commit the crime of perjury,
and of humanity, because it would prevent the extorting of
confessions by duress.
Facts:
The 3 accused were charged with kidnapping Felix
Punsalan without giving any information about him nor did they
provide any evidence to show that they already set him free.
During the trial the prosecution presented 3 witnesses. Along
with these witnesses one of the defendants, Marcelo De Leon,
took the witness stand and claimed that his other 2 co-accused
did kidnap Punsalan and that his knowledge about the matter
was brought by him being one of the kidnappers. The trial court
Imprisonment in accordance with Art 483 of the Penal Code.
Relevant Issue:
Whether or not the law can compel the accused to
witness against himself for fear of harsher punishment?
Ruling: NO
Ratio:
The right against self-incrimination was established on
the grounds of public policy and humanity — of policy, because
if the party were required to testify, it would place the witness
under the strongest temptation to commit the crime of perjury,
and of humanity, because it would prevent the extorting of
confessions by duress.
It had its origin in a protest against the inquisitorial
methods of interrogating the accused person, which had long
obtained in the continental system.
In other words, the very object of adopting this provision
of law was to wipe out such practices as formerly prevailed in
the Philippines under the Spanish rule that requires the accused
to submit to judicial examinations, and to get testimony
regarding the offense with which they were charged or if they
refuse face stricter punishment.
It must be remembered that It is the prosecution that has
a duty, in order to convict one of a crime, to produce evidence
showing guilt beyond a reasonable doubt; and the accused
cannot be called upon either by express words or acts to assist in
the production of such evidence; nor should his silence be taken
as proof against him. He has a right to rely on the presumption
of innocence until the prosecution proves him guilty of every
element of the crime with which he is charged.