Res Inter Alios Acta Rule: Admissions and Confessions Under Rule 130 (Evidence)

The Res Inter Alios Acta Rule is a foundational principle in evidence law under Rule 130 of the Rules of Court in the Philippines. This Latin maxim translates to “a thing done between others,” and it embodies the principle that the rights of a party cannot be prejudiced by the acts, declarations, or omissions of others. This rule is highly relevant to admissions and confessions, especially when applied in testimonial evidence.

I. The General Principle

Under Section 28 of Rule 130 of the Rules of Court:

"The rights of a party cannot be prejudiced by an act, declaration, or omission of another, except as hereinafter provided."

This general rule prohibits the use of acts, declarations, or omissions made by a third party to affect another person's rights unless an exception applies.

II. Two Aspects of Res Inter Alios Acta

Acts or Declarations as Evidence Against a Third Party
- The general principle is that the acts, declarations, or omissions of a person cannot be used to bind or prejudice another who was not privy to such acts or declarations.
- Illustrative Example:
  If Person A confesses to a crime, Person B cannot automatically be implicated or prejudiced based on Person A’s confession unless an exception applies.
Relevance to Admissions and Confessions
- An admission (statement of fact by a party against their interest) or a confession (direct acknowledgment of guilt in a criminal matter) made by one individual cannot bind or prejudice another person unless there is a recognized exception.
- This is to safeguard the due process rights of individuals and ensure that evidence is reliable and fair.

III. Exceptions to the Rule

The Res Inter Alios Acta Rule is not absolute. Exceptions are enumerated in the Rules of Court, including situations where the acts, declarations, or omissions of one person may affect another. These are as follows:

Admissions by a Co-Party (Sec. 29)
- The act, declaration, or omission of one party may be received in evidence against a co-party if:
  - A joint interest exists between the parties at the time of the act, declaration, or omission.
  - The admission relates to the joint interest.
- Example:
  In a civil case involving co-owners of a property, one co-owner’s admission about the property may be used against the other co-owners.
Admissions by a Third Person (Sec. 30)
- The declaration of a third person can be evidence against a party if:
  - The third person was acting as the agent of the party at the time the declaration was made.
  - The third person’s declaration relates to the matter within the scope of their authority.
- Example:
  A corporate officer’s statement about the company’s liability can bind the corporation.
Admissions by Privies (Sec. 31)
- The rights of a party can be affected by the declarations, acts, or omissions of another if the latter stands in privity with the party.
- Example:
  The admission of a predecessor-in-interest in relation to property rights can bind the successor.
Confessions of a Co-Accused (Sec. 12, Rule 119)
- In criminal cases, the extrajudicial confession of an accused implicating a co-accused is admissible against the co-accused only if:
  - The confession was made in the presence of the co-accused, and
  - The co-accused had the opportunity to confront and cross-examine the confessant.
- Absent these conditions, the confession is considered hearsay and inadmissible as evidence against the co-accused.

IV. Rationale Behind the Rule

Protection of Rights:
- The rule ensures that an individual is not unfairly prejudiced by acts or declarations they had no participation in or control over.
Relevance to Due Process:
- A person’s liability, whether civil or criminal, must be determined based on competent, relevant, and credible evidence that directly pertains to them.
Promotion of Reliable Evidence:
- The rule prevents the introduction of unreliable or irrelevant evidence that could lead to injustice.

V. Practical Applications

Civil Cases:
- A party’s statements or admissions can bind them but cannot be used to prejudice others unless a recognized exception applies.
- Example: In a case of breach of contract, statements made by a non-party to the contract are generally inadmissible unless the non-party is shown to be an agent or privy.
Criminal Cases:
- The confession of an accused cannot automatically implicate others unless corroborated by other evidence or made in the presence of the implicated party.
Agency Relationships:
- Statements made by an agent within the scope of their authority can bind the principal. This exception recognizes the principle of representation in legal relationships.

VI. Case Law Interpretations

People v. Castillo (G.R. No. 192707, June 5, 2013):
- The Supreme Court emphasized that a co-accused's confession implicating another is inadmissible unless made in the presence of the latter or under the exceptions in Rule 119.
Heirs of Coscolluela v. Rico General Insurance (G.R. No. 175955, November 17, 2010):
- The Court ruled that declarations of a party’s predecessor-in-interest are admissible against the party as an exception to the rule.
People v. Andaya (G.R. No. 147837, March 14, 2003):
- A confession implicating another accused, not made in their presence, was declared inadmissible because it violated the Res Inter Alios Acta rule.

VII. Conclusion

The Res Inter Alios Acta Rule under Rule 130 embodies a fundamental protection in the rules on evidence. While the general rule excludes acts, declarations, and omissions of third parties from prejudicing others, the enumerated exceptions ensure that evidence remains relevant, fair, and consistent with the demands of justice. The application of the rule, particularly in admissions and confessions, underscores the judiciary’s commitment to safeguarding individual rights and upholding due process.