PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. OLIVIA ALETH GARCIA CRISTOBAL, ACCUSED-APPELLANT. Summary

PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. OLIVIA ALETH GARCIA CRISTOBAL, ACCUSED-APPELLANT.

G.R. No. 159450 | 2011-03-30

Due process safeguards when accused waives right to present evidence; duty of the trial court to observe a procedure akin to a "searching inquiry"
Letter not an extrajudicial confession since not contain an acknowledgment of guilt; but as a voluntary admission, not need to be under oath or assisted by counsel to be admissible)

THIRD DIVISION

D E C I S I O N

BERSAMIN, J.:

Although a waiver of the right to present evidence by the accused is not a trivial matter to be lightly regarded by the trial court, the filing of the demurrer to evidence without express leave of court operates as a waiver that binds the accused pursuant to the express provision of the Rules of Court.

Under challenge in this appeal is the decision promulgated on July 31, 2003 in C.A.-G.R. CR No. 24556, whereby the Court of Appeals (CA) affirmed the conviction for qualified theft of the accused, a teller of complainant Prudential Bank, and punished her with reclusion perpetual,¹...