OFFER OF COMPROMISE

People v. Charlie Nazareno,

G.R. No. 180915, Aug. 9, 2010
Perez, J.:

DOCTRINE:
Section 27 (NOW SECTION 28). Offer of compromise not
admissible
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In criminal cases, except those involving quasi-offense (criminal
negligence) or those allowed by law to be compromised, an offer
of compromise by the accused may be received in evidence as an
implied admission of guilt.

FACTS:
Accused-appellant Nazareno was charged with murder by
stabbing the victim, Romeo De Guzman. Appellant pleaded not
guilty upon arraignment. Thereafter, trial of the case was
proceeded. During trial, appellant admitted having written a letter
to the victim’s brother asking the latter’s forgiveness. The trial
court rendered a decision convicting the appellant. Upon appeal,
the CA affirmed the RTC decision but modified the award on the
civil aspect of the case.

ISSUE:
 Whether or not the letter written by the appellant to the
victim’s brother asking for forgiveness is admissible in evidence
against him.

RULING:
Yes, the letter is admissible in evidence against the
appellant. The Supreme Court held that appellant’s act of
pleading for forgiveness may be considered as analogous to an
attempt to compromise, which in turn, can be received as an
implied admission of guilt under Section 27, Rule 130 of the Rules
of Court (now Section 28 of Rule 130 of the Amended Rules on
Evidence)