G.R. No. L-3544; April 18, 1952
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMETERIO SASOTA, ET AL., defendants; EMETERIO SASOTA and ALEJO SANCHEZ, defendants-appellants.

FACTS

In the Court of First Instance of Camarines Sur, Emeterio Sasota, Alejo Sanchez, Pablo Sanchez, and Juan Sanchez were accused of murder for killing Sabino Bucad. After trial, during which Pablo Sanchez and Juan Sanchez died, the court found Emeterio Sasota and Alejo Sanchez guilty of murder and sentenced each to reclusion perpetua, joint and several indemnity of P2,000 to the heirs of Sabino Bucad, and proportional costs. The appellants appealed the decision.
The prosecution evidence established that around 10:00 PM on October 17, 1943, Sabino Bucad was taken from his house in Masoli, Bato, Camarines Sur, by four armed men identified as the two appellants and their two co-accused. Sabino’s son, Arsenio Bucad, witnessed the appellants and their companions, armed with bolos, call for Sabino, tie his hands upon his descent, and take him away, after which Arsenio heard sounds of beating and groans. The group, with their bound victim, was seen by barrio lieutenant Eladio Barbacena, who was threatened by Juan Sanchez when he inquired. Barbacena secretly followed them to Bato lake, where he saw Sabino placed in a banca and taken toward the opposite shore, hearing Sabino groaning and asking for forgiveness. Witness Pablo Villez, who also followed the group, saw the four accused take turns beating Sabino in the banca until he died, and later informed Arsenio of this. Another witness, Roman Arbo, saw appellant Sasota pulling the tied Sabino, followed by the others, with Juan Sanchez beating the victim. Sabino’s body was never found. The appellants denied involvement, interposing alibi, and challenged the establishment of corpus delicti due to the absence of the body.

ISSUE

Whether the corpus delicti (the fact of death and criminal agency causing it) was sufficiently established despite the body of Sabino Bucad never being found.

RULING

Yes. The Supreme Court affirmed the conviction, modifying the indemnity to P6,000. The Court held that in murder or homicide cases, it is not necessary to recover the body or indicate its whereabouts. The death and the criminal agency causing it may be proven, and in cases like death at sea or where the body is destroyed or disappears, both elements may be established by circumstantial evidence. Citing Wharton and Francisco on Criminal Evidence, the Court emphasized that death can be proved circumstantially, such as through witness testimony showing the victim’s condition, the nature of wounds, and the impossibility of rescue. Here, multiple witnesses credibly testified to seeing the appellants take Sabino, tie his hands, beat him during a boat journey on the lake, and heard his pleas and groans until he died. The Court found the prosecution witnesses’ testimonies natural, probable, and without motive to falsely accuse, rejecting the appellants’ alibi. Conspiracy among all accused was evident from their concerted actions from the abduction to the killing, making each responsible for the acts of all. The Court also noted a possible motive: Pablo Sanchez’s illicit relations with Sabino’s common-law wife, with the other appellants assisting due to familial or friendly ties. Thus, corpus delicti was established through circumstantial evidence, and no reversible error was found in the trial court’s decision.