G.R. No. 101442 March 28, 2001
JOSE ANGELES, JR., petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Jose Angeles, Jr., along with several others, was charged with Robbery for the hijacking of a delivery truck carrying goods worth P384,384.81 belonging to the Philippine Refining Company on December 17, 1984. The prosecution evidence established that the truck was flagged down by co-accused Andres Tello, a fellow driver. Tello’s two companions, who boarded the truck, later brandished a gun and a grenade, declared a hold-up, and diverted the vehicle to Davao City. The stolen goods were unloaded at a house rented by petitioner. Tello, who was discharged to become a state witness, testified that petitioner was the mastermind who planned the robbery at a meeting in his house, threatening harm to anyone who would back out.
The Regional Trial Court convicted petitioner. The Court of Appeals affirmed the conviction but modified the penalty. Petitioner appealed, arguing that the testimony of the discharged co-accused, Andres Tello, was uncorroborated and insufficient to prove guilt beyond reasonable doubt.

ISSUE

Whether the testimony of a discharged co-accused, without corroboration, is sufficient to sustain a conviction for robbery.

RULING

Yes, the conviction is proper. The Supreme Court held that the testimony of a discharged co-accused, provided it satisfies the court regarding its truthfulness, can be sufficient to sustain a conviction even without corroboration. The Court emphasized that the requirement for corroboration applies to the testimony of an accomplice, not to a state witness who has been discharged in accordance with the Rules of Court. The discharge of Tello was properly granted by the trial court after determining his testimony was absolutely necessary and he did not appear to be the most guilty. His testimony was found to be credible, clear, and consistent, directly linking petitioner as the planner of the robbery and the beneficiary of the stolen goods, which were stored in his rented house and later found at his marketing company.
The Court further ruled that conspiracy was adequately proven. Direct proof is not essential; conspiracy can be inferred from the acts of the accused before, during, and after the crime indicating a common purpose. Petitioner’s role as the planner and the destination of the hijacked goods to his premises demonstrated concerted action. The crime committed was Robbery under Article 294(5) of the Revised Penal Code. With no modifying circumstances, the penalty was properly imposed within the medium period. Applying the Indeterminate Sentence Law, the Court of Appeals correctly sentenced petitioner to an indeterminate penalty of four (4) years of prision correccional, as minimum, to eight (8) years of prision mayor, as maximum. The petition was denied.