G.R. No. L-33046 February 18, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PASCUAL CUYA, JR., defendant-appellant.

FACTS

Pascual Cuya, Jr. appealed his conviction for robbery with homicide by the Court of First Instance of Batangas, which sentenced him to reclusion perpetua. The prosecution’s case primarily rested on the testimony and extrajudicial confession of his co-accused, Lorenzo del Carmen. Del Carmen testified that on April 6, 1970, in Alitagtag, Batangas, he and Cuya, needing money to return to Manila, followed the victim, Ruben Marasigan. Cuya, armed with a bamboo club, struck Marasigan twice. Del Carmen then took the club and also struck the victim. They carried the body to a creek, where Cuya took P40 from the victim, giving half to Del Carmen. The autopsy confirmed a fatal skull fracture.
Cuya pleaded not guilty and presented an alibi, claiming he was on a picnic elsewhere. He argued he was implicated because he had assisted the police in apprehending Del Carmen. The trial court rejected his defense. On appeal, Cuya challenged the sufficiency of Del Carmen’s uncorroborated testimony as a co-conspirator to establish guilt beyond reasonable doubt.

ISSUE

Whether the testimony of a co-conspirator, Lorenzo del Carmen, alone and without corroboration, is sufficient to prove the guilt of Pascual Cuya, Jr. for robbery with homicide beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction, applying an exception to the general rule that a co-conspirator’s testimony requires corroboration. The general rule cautions against reliance on such testimony due to its potentially polluted source, as a confessing culprit may shift blame. However, an exception exists where the testimony is shown to be sincere, given unhesitatingly and straightforwardly, and is replete with details that could not be the product of deliberate afterthought.
The Court found that Del Carmen’s testimony fell within this exception. He had initially given an extrajudicial confession implicating Cuya, which he subsequently ratified during the preliminary investigation and in his court testimony. The trial court characterized his delivery as “spontaneous.” The detailed account of the crime, including the motive, the weapon used, the manner of the attack, and the division of the stolen money, carried the ring of truth. Furthermore, the autopsy finding of a gunshot wound in addition to the skull fractures lent credence to Del Carmen’s statement that there were two assailants. The Court thus held that Del Carmen’s credible and consistent testimony alone was sufficient to establish Cuya’s guilt beyond reasonable doubt for robbery with homicide, as the killing was perpetrated by reason of the robbery. The judgment was affirmed with an increase in the civil indemnity.