G.R. No. L-4847 May 15, 1953
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MOROS ANSANG, ET AL., defendants. MORO ANSANG and MORO JUBAIL, defendants-appellants.

FACTS

Moros Ansang, Jubail, and Jaho were charged with multiple murder before the Court of First Instance of Zamboanga. Moro Jaho was acquitted, but Moros Ansang and Jubail were convicted and sentenced to reclusion perpetua, indemnity, and costs. They appealed. Ansang had complained to the Chief of Police of Maluso that Moro Berto was taking coconuts from his plantation. On October 7, 1949, Jubail (Ansang’s foster son) saw Berto, Abdani, Eka, and Kasim loading copra from the plantation onto a vinta bound for Isabela. A few days later, Abdul Samad saw Jubail and Jaho boarding a vinta, with Jubail carrying three homemade bombs, which he claimed were for fishing. When they returned, they had no bombs and brought no fish. Berto and his three companions were never seen again. Pieces of Berto’s vinta were later found on the shore of Pilas island. During investigation, Ansang and Jaho made written confessions. Ansang’s confession stated that, due to Berto taking his copra, he ordered Jubail to gather bombs; Jubail then, with Jaho as helmsman, followed Berto’s vinta, threw bombs at it, destroying it and causing the disappearance of the four occupants. Jaho’s confession stated he was invited to go fishing, was surprised when Jubail threw bombs at Berto’s vinta, and would not have accompanied him had he known the purpose. At trial, the defendants did not challenge the validity of their confessions, offering only a general denial.

ISSUE

Whether a conviction can be based on an extrajudicial confession without independent proof of the corpus delicti.

RULING

Yes, the conviction is valid. The court held that while a conviction cannot be based solely on an extrajudicial confession without proof of the corpus delicti independent of the confession, such independent proof exists in this case. The corpus delicti (the fact that a crime has been committed) is established by evidence separate from the confessions: Jubail was Ansang’s foster son and Ansang had a grudge against Berto; Jubail and Jaho were seen sailing with three hand grenades, claiming to go fishing; they returned without grenades or fish; Berto and his companions vanished after their trip; and wreckage of Berto’s vinta was found. This evidence independently shows that Berto and his companions met a violent death due to a criminal act. The court cited U.S. vs. Valdez and People vs. Marquez, explaining that the corpus delicti does not require the physical body of the victim or the stolen object to be produced, but only requires some evidence, apart from the confession, tending to show that a crime was committed. The decision was affirmed with the modification that the indemnity was increased to P6,000.