GR L 146; (May, 1946) (Digest)
G.R. No. L-146; May 7, 1946
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANGEL CRUZ Y ENCARNACION, defendant-appellant.
FACTS
The accused, Angel Cruz y Encarnacion, was convicted by the Court of First Instance of Manila of attempted qualified theft and sentenced to twenty days of arresto menor. The prosecution’s case rested primarily on an extra-judicial confession (Exhibit A) signed by the accused. In this confession, he admitted to having previously taken and sold four cases of batteries from the Sta. Mesa Signal Depot and to having attempted to take eight more cases on May 12, 1945. The confession was obtained after Sgt. Robert C. Cooper arrested the accused based on information from Pablo Lisan (who was apprehended while attempting to remove batteries) and Rafael Advincula, both of whom implicated the accused. The prosecution witnesses, Justo Camat and Ormond D. Abbot, testified only that the accused understood and voluntarily signed the confession. The accused denied any involvement with Lisan or Advincula and testified that he signed the confession because Sgt. Cooper boxed him in the stomach, threatened him with a pistol, and forced him to sign while they were alone. Sgt. Cooper, in rebuttal, denied using any force or intimidation.
ISSUE
Whether the accused’s conviction, based primarily on his uncorroborated extra-judicial confession, can be sustained given the lack of independent evidence of the corpus delicti.
RULING
No. The Supreme Court acquitted the accused and dismissed the case. The Court held that the guilt of the appellant was not proven beyond reasonable doubt. The conviction relied mainly on the extra-judicial confession. Even assuming the confession was voluntary, it was insufficient to sustain a conviction because it was not corroborated by evidence of the corpus delicti as required by Section 96, Rule 123 of the Rules of Court. The only testimony regarding the corpus delicti came from Sgt. Cooper, which was hearsay. He testified that he did not personally witness the theft attempt but that Sgt. Tom Reilly apprehended Pablo Lisan. His testimony about the information given to him by Lisan and Advincula implicating the accused was also hearsay. These hearsay statements, having been objected to, could not be considered as evidence of the corpus delicti. In the absence of such corroborative evidence, the confession alone was inadequate for conviction. The Court, therefore, found the Solicitor General’s recommendation for acquittal well-founded.