Evid Cases: People v. Godoy and Anderson v. US

People v. Godoy GR. 115908-09, December 6, 1995 Facts: Danny Godoy is a teacher of Palawan National School. He was accused before the RTC and was subsequently convicted for the separate crimes of Rape and Kidnapping with Serious Illegal Detention. The case was a product of an alleged several and repeated assaults committed against the virtue of Godoy’s student, Mia Taha, a girl 17 years of age. During the time that Danny Godoy was detained, that is, prior to the commencement of the criminal case against him, the mother of Danny went to Mia and her parents to settle the case. All of them settled before the office of the prosecutor where, upon payment, Mia executed an affidavit of desistance. DANNY WAS NOT AWARE OF SUCH SETTLEMENT. Nonetheless the case persisted and Godoy was meted out the penalty of death. The case went to the Supreme Court by Automatic Review. Issue: What is the effect of settlement in the Criminal Case? Held: Danny Godoy was absolved and was acquitted. This is because he has successfully casted doubt as to the guilt imputed against him. His Hi s “sweet heart theory” was given give n course because it was more consonant with the ordinary human behaviour from the events that transcribed. On the contrary, Mia Taha’s version of the story is marred with substantial inconsistencies which run contrary to her assertions. As to the settlement, the court ruled that: “In criminal cases, an offer of compromise is generally admissible as evidence against the party making it. No compromise whatever may be entered into as regards the penal action. It has long been held, however, that in such cases the accused is permitted to show that the offer was not made under a consciousness of guilt, but merely to avoid the inconvenience of imprisonment or for some other reason which would justify a claim by the accused that the offer to compromise was not in truth an admission of his guilt or an attempt to avoid the legal consequences which would ordinarily ensue therefrom.” therefrom. ” “. . . appellant did not know, not until the trial proper, that his mother actually paid P30,000.00 for the settlement of these cases. Complainant's own mother, Helen Taha, testified that present during the negotiations were herself, her husband, Mia, and appellant's mother. Appellant himself was never present in any of said meetings. It has been held that where the accused was not present at the time the offer for monetary consideration was made, such offer of compromise would not save the day for the prosecution. In another case, this Court ruled that no implied admission can be drawn from the efforts to arrive at a settlement outside the court, where the accused did not take part in any of the negotiations and the effort to settle the case was in accordance with the established tribal customs, that is, Muslim practices and traditions, in an effort to prevent further deterioration of the relations between the parties.”

Anderson v. United States 417 U.S. 211 June 3, 1974 Facts: For having conspired to cast fictitious votes for federal, state, and local candidates in a West Virginia primary election, petitioners were convicted of violating 18 U.S.C. 241, which makes it unlawful to conspire to injure any citizen in the free exercise or enjoyment of any right or privilege secured by the Constitution or laws of the United States. At the trial, over petitioners' objections, certain statements made by two of the petitioners at a local election contest hearing held after the election results had been certified on May 27, 1970, were admitted in evidence against all the petitioners to prove that the two petitioners making the statements had perjured themselves at the election contest hearing. On appeal, the petitioners contended for the first time that 241 was limited to conspiracies to cast false votes in federal elections, and that accordingly the conspiracy charged in their case, as far as federal  jurisdiction was concerned, concerned, ended on May 27, so that subsequent out-of-court statements statements could not have furthered any 241 conspiracy and hence should not have been admitted in evidence. The Court of Appeals rejected these contentions, and affirmed the convictions. Issue: Whether or not the statements of his co-conspirators are admissible as evidence against him. Held: The out-of-court statements were admissible under basic principles of the law of evidence and conspiracy, regardless of whether or not 241 encompasses conspiracies to cast fraudulent votes in state and local elections. The statements were not hearsay, since they were not offered in evidence to prove the truth of the matter asserted; hence their admissibility admissibility was governed by the rule that acts of one alleged conspirator can be admitted into evidence against the other conspirators, if relevant to prove the existence of the conspiracy, even though they may have occurred after the conspiracy ended.