GR 40553; (August, 1934) (Digest)
G.R. No. 40553 ; August 17, 1934
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. FRANCISCO BUADA, ET AL., defendants. FRANCISCO BUADA, appellant.
FACTS
Appellant Francisco Buada was convicted of robbery for breaking into a house on May 10, 1931, and stealing a trunk containing money and property. The trunk was found discarded nearby. The prosecution initially relied on a witness who claimed to see Buada and others armed at the scene, but the trial court found this witness hostile and unreliable, discharging the other accused. The conviction was instead based on evidence that, months after the robbery, a stolen necklace was found in the possession of Marcelina Mendoza, who testified she bought it from Buada in May. Her husband corroborated her testimony and added that Buada attempted to repurchase the necklace and threatened them to prevent truthful testimony.
ISSUE
The main issue is whether the trial court erred in convicting Buada based on the testimony of Marcelina Mendoza and her husband, despite discrediting the initial eyewitness, and whether possession and sale of a single stolen item is sufficient evidence to prove the robbery of all items taken.
RULING
The Supreme Court affirmed the conviction. It held that the maxim “falsus in uno, falsus in omnibus” does not require discarding all prosecution evidence if one witness is false; it applies only where the false testimony is so material it impugns the witness’s entire character. The Court found the testimony of Marcelina Mendoza and her husband credible and sufficient. It further ruled that the possession and sale of a part of the stolen property warrants the inference that the accused stole all of it. The trial court’s assessment of witness credibility was upheld, and the evidence established Buada’s guilt beyond a reasonable doubt. The sentence was modified to a minimum of one year of prision correccional under the Indeterminate Sentence Law.
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