G.R. No. 136996 - Alcantara vs. Reta, Jr.

The City Attorney of Quezon City filed an amended information on March 22, 1955, charging Juan Consunji, Alfonso Panganiban, and an unknown third party with conspiracy to murder Jose Ramos (Criminal Case No. Q-1G37, CFI Quezon City).
The People of the Philippines as petitioner versus Hon. Nicasio Yatco (trial judge), Juan Consunji, and Alfonso Panganiban as respondents.

Trial commenced on May 3, 1955; the prosecution presented witness testimony, including NBI Atty. Arturo Xavier regarding an extrajudicial confession by Consunji.
On May 18, 1955, Panganiban’s counsel objected to the confession evidence as hearsay against Panganiban; the trial court excluded all evidence of both confessions on its own ground that conspiracy had not been established by prior proof, citing Section 12, Rule 123, Rules of Court.
The prosecution’s motion for reconsideration of the exclusion order was denied.

The Solicitor General petitioned this Court via certiorari to annul the trial court’s exclusion order.
The petition argued that the trial court abused its discretion by completely excluding Consunji’s confession—a freely and voluntarily made extrajudicial confession admissible under Section 14, Rule 123—even if not competent against the co-accused.

Whether the trial court properly excluded the extrajudicial confessions of Consunji and Panganiban without prior proof of conspiracy.
Whether Section 14, Rule 123, permits the admission of an accused’s extrajudicial confession as evidence against himself notwithstanding hearsay objections by co-accused.
Whether the trial court may, on its own motion, exclude evidence on grounds not raised by the parties.