People v. Maqui Case Digest

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 compromise are admitted. | An offer of compromise, 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.

H unte er: If the accused, under a guilt y conscience, 4. US v. Hunt 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 our current case:  Since Maqui made the extrajudicial statements voluntarily, then his statements can be admitted.  State v. Bruc Br uce e: An offer of compromise, voluntarily made 5. Stat by the accused,  without threat or promise, and the reply thereto, are admissible in evidence upon his trial for a crime. 6. Stat  State v. Rodri Rodri guez guez: 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] hah a] 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 affiliatio n, but I think he contradicted himself in that statement. Hence, the penalty applicable to Maqui is that of   presidio correccional  in  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.