Accused extrajudicial statement may NOT be used as evidence unless repeated in open court
The extrajudicial statements of an accused implicating a co-accused may not be utilized against the latter, unless these are repeated in open court. If the accused never had the opportunity to cross-examine his co-accused on the latters extrajudicial statements, it is elementary that the same are hearsay as against said accused. That is exactly the situation, and the disadvantaged plight of appellants, in the case at bar. [G.R. No. 119005. December 2, 1996]