G.R. No. 77397; April 3, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RONALDO JOMAO-AS y PADILLA and ALEXANDER SPANDONIS alias “BRUTUS”, defendants, ALEXANDER SPANDONIS alias “BRUTUS”, defendant-appellant.

FACTS

On June 29, 1985, NARCOM agents arrested Ronaldo Jomao-as during a buy-bust operation in Davao City for selling five matchboxes of marijuana. Upon interrogation, Jomao-as pointed to Alexander Spandonis as his source. Consequently, both were charged with violating the Dangerous Drugs Act. Jomao-as later pleaded guilty to a lesser offense. Spandonis pleaded not guilty, claiming he was painting his sister’s house at the time and that Jomao-as implicated him due to a prior grudge.
The trial proceeded against Spandonis. The prosecution’s case hinged primarily on the testimony of his co-accused, Jomao-as. Another witness, Joseph Cagas, testified that he also obtained marijuana from Spandonis in a separate incident on July 9, 1985. The trial court convicted Spandonis, sentencing him to life imprisonment and a fine.

ISSUE

Was the uncorroborated testimony of a co-accused sufficient to convict Alexander Spandonis beyond reasonable doubt?

RULING

No. The Supreme Court reversed the conviction and acquitted Spandonis on the ground of reasonable doubt. The Court emphasized that while no law generally requires corroboration of a witness’s testimony, an exception exists for the testimony of a self-confessed accomplice or co-conspirator. Such testimony, coming from a “polluted source,” cannot by itself be considered proof to a moral certainty. It must be substantially corroborated in all material points by other evidence.
Here, the conviction rested almost entirely on the uncorroborated testimony of Jomao-as. The Court found the testimony of Joseph Cagas unreliable and insufficient for corroboration. Cagas’s claim that he bought marijuana from Spandonis on July 9, 1985, was incompatible with the prosecution’s own evidence that Spandonis was under close surveillance after June 29. No report or arrest from such a surveillance was presented, casting doubt on Cagas’s credibility. With no other credible evidence linking Spandonis to the marijuana, the prosecution failed to meet the required standard of proof beyond reasonable doubt. Given this disposition, the Court deemed it unnecessary to rule on the ancillary issue regarding the lack of preliminary investigation.