On Extrajudicial Confession

The news item says: "With this, La Viña said there is no need to prove Duterte’s remark to the International Criminal Court because there is an admission."  The esteemed Dean made the same remark in the context of impeachment.

But the Supreme Court did say this:

"And according to Section 3, Rule 133 of the Rules of Court:

Extrajudicial confession, not sufficient ground for conviction.—An extrajudicial confession made by an The news item says: "With this, La Viña said there is no need to prove Duterte’s remark to the International Criminal Court because there is an admission."

CLEMENTE MAGTOTO, petitioner, vs. HON. MIGUEL M. MANGUERA, Judge of the Court of First Instance (Branch II) of Occidental Mindoro, The PEOPLE OF THE PHILIPPINES, IGNACIO CALARA, JR., and LOURDES CALARA, respondents. [G.R. Nos. L-37201-02 March 3, 1975]

With all due respect, Dean La Viña might have been referring to a judicial admission under Section 4, Rule 129 of the Rules of Court, which states:

“SECTION 4. Judicial Admissions.An admission, verbal or written, made by a party in the course of the proceedings in the same case, does not require proof. The admission may be contradicted only by showing that it was made through palpable mistake or that no such admission was made.”

But Rule 116 is even explicit in that the prosecution is still required to present evidence, thus:

“Section 3. Plea of guilty to capital offense; reception of evidence. — When the accused pleads guilty to a capital offense, the court shall conduct a searching inquiry into the voluntariness and full comprehension of the consequences of his plea and require the prosecution to prove his guilt and the precise degree of culpability. The accused may present evidence in his behalf. (3a)”, shall not be sufficient ground for conviction, unless corroborated by evidence of corpus delicti."