G.R. No. L-6481 / March 21, 1911
THE UNITED STATES, plaintiff-appellee, vs. QUINTIN MONDEJAR, defendant-appellant.

FACTS

On the afternoon of June 18, 1910, merchant Chiong Uco was returning from Sagay to Cadiz in Occidental Negros. In an uninhabited place, he met and spoke to the defendant, Quintin Mondejar, whom he knew. After passing him, Mondejar suddenly attacked Uco from behind with a bolo, inflicting a severe wound on his head. When Uco pleaded, “Quintin, do not kill me; if it is money you want, I will give it to you,” Mondejar struck him two more times, rendering him unconscious. Upon regaining consciousness, Uco discovered that the P200 he was carrying was gone. No other witnesses were present. Uco immediately reported the crime to the justice of the peace, identifying Mondejar as the perpetrator. The Court of First Instance convicted Mondejar of robbery with wounds.

ISSUE

Is the uncorroborated testimony and identification of a single witness (the victim) sufficient to sustain a conviction for robbery with wounds?

RULING

Yes. The Supreme Court affirmed the conviction but modified the penalty. The testimony of a single witness is sufficient for conviction if it is credible, direct, positive, clear, conclusive, free from contradictions, and establishes guilt beyond a reasonable doubt. In this case, the victim was well-acquainted with the appellant, addressed him by name during the attack, and promptly reported the crime. His testimony met the standard for conviction. The Court clarified that its prior rulings in U.S. vs. Cabe and U.S. vs. Asiao did not establish a rule requiring corroboration; they merely emphasized that uncorroborated testimony is insufficient if it is discredited by circumstances or contradictions. The crime was qualified by the generic aggravating circumstances of alevosia (treachery, by attacking from behind) and despoblado (uninhabited place), with no mitigating circumstances. The penalty for robbery with wounds under the relevant provisions of the Penal Code was therefore imposed in its maximum degree. The judgment was affirmed with the modification that the penalty be fixed at fourteen years and eight months of cadena temporal.