G.R. No. 9230 - People vs. Corrales

Case Summary (G.R. No. 9230)

Factual Background

On June 6, 1913, Jose Corrales, then clerk of the Court of First Instance of Misamis, received PHP 321.88 from a Chinaman named Melliza as payment of a fine and costs. Instead of issuing the prescribed official receipt, Corrales handed Melliza a copy of the judgment of conviction bearing the notation "Multa y costas pagadas." On June 13, 1913, the district auditor inspected the property, books, and accounts submitted by Corrales. The amount of PHP 321.88 was not turned over at the inspection, was not found among the funds or property of Corrales, and no reference to its payment appeared during the audit.

Trial Court Proceedings

An information for misappropriation of public funds was filed against Corrales before 12 o'clock on June 14, 1913. The court below convicted Corrales and sentenced him to nine months' imprisonment and to pay the costs of the trial. Corrales appealed to this Court.

The Accused's Account

At trial Corrales admitted receipt of the money but testified that he was busy when he received it and, lacking time to enter the transaction in the office books, placed the money in the drawer of the safe where he kept his personal funds, intending later to make the proper entry. He claimed to have forgotten the incident until after the auditor concluded the inspection, that he never withdrew the money, that upon recollection he prepared an official receipt for Melliza and then informed the auditor of the matter.

Prosecution Evidence

The district auditor testified that, a few hours after the information was filed, Corrales went to the auditor's house and stated that the money was in the office safe. The auditor asked when Corrales had put it there, and Corrales admitted that he had placed the money in the safe at about half past 5 in the afternoon of June 13, after the inspection had been completed. The auditor's testimony as to this admission was not disputed by defense counsel on its truth, although counsel challenged its competency.

Legal Issue Presented

Counsel for Corrales contended that the auditor's testimony as to the accused's statement was incompetent because the prosecution failed to show that the extrajudicial statement was made freely and voluntarily and because it was not made under oath. The narrow legal question before the Court was whether the statutory foundation required for the admission of extrajudicial confessions applied to the auditor's evidence of Corrales' statement and whether the absence of oath rendered the statement inadmissible.

Court's Analysis on Confession and Admission

The Court distinguished between a confession and an admission. A confession, the Court explained, is a voluntary declaration acknowledging commission or participation in a crime and is subject to the statutory rule that it is inadmissible unless the prosecution first proves it was made freely and voluntarily. An admission, by contrast, is a statement of fact by the accused that does not directly acknowledge guilt or criminal intent but may, in conjunction with other circumstances, support an inference of guilt. The Court held that the statutory provision excluding extrajudicial confessions unless a foundational showing is made does not apply to admissions.

Evidentiary Ruling

The Court concluded that the auditor's testimony describing Corrales' statement was admissible as evidence of an admission, not as an extrajudicial confession, and that no law required that admissions be made under oath to be competent. The Court observed that nothing in the record suggested the statement was made under duress and that the trial judge properly considered the admission in weighing the evidence. The Court accepted the trial judge's finding that the narrative offered by Corrales at trial was false i

Case Syllabus (G.R. No. 9230)

Parties and Procedural Posture

The United States prosecuted the case below and was the appellee on appeal.
Jose Corrales was the defendant below and the appellant in the present appeal.
The appellant was convicted in the lower court of misappropriation of public funds and was sentenced to nine months' imprisonment and to pay the costs of the trial.
The conviction was appealed to the Court that issued the present decision.

Key Factual Allegations

On June 6, 1913, the accused received P321.88 from a Chinaman named Melliza as the amount of a fine and costs imposed upon Melliza.
Instead of issuing the prescribed official receipt, the accused handed Melliza a copy of the judgment with the notation "Multa y costas pagadas."
On June 13, 1913, the district auditor examined the accused's property, books, and accounts after those items had been submitted by the accused for inspection.
The sum of P321.88 was not turned over to the auditor, was not found among the funds or property of the accused, and the inspection developed no reference to its payment.
An information charging misappropriation was filed the day after the inspection, June 14, 1913.
A few hours after the information was filed, the accused informed the auditor that the amount was in the office safe in the drawer where he kept his personal funds.

Defense Account

The accused testified that he was busy when he received the money and, having no time to enter the receipt in the office books, placed the money in the drawer of the safe where he kept his personal funds intending to make the proper entry later.
The accused asserted that he forgot about the money until after the auditor's inspection and that the money remained untouched and was never withdrawn by him.
The accused stated that after recalling the transaction following inspection he prepared an official receipt for Melliza and then informed the auditor.

Trial Court Findings

The trial judge found the accused's testimony to be false and concluded that the accused had misappropriated the funds.
The tria