G.R. No. L-429; August 21, 1946
EL PUEBLO DE FILIPINAS, querellante y apelado, vs. FELIX MARQUEZ, acusado y apelante.

FACTS

On the morning of December 30, 1945, while Emeterio Manuel was walking on Dapitan Street in Manila, an unknown individual approached him, showed a revolver tucked in his waist, and demanded P10, saying, “¿No tienes miedo a esto?” Immediately thereafter, the accused-appellant Felix Marquez approached, took Manuel’s wallet, and removed all the money inside, amounting to P20. Terrified, Manuel did not resist. The assailants left, and Manuel reported the incident to the police on España Street. Shortly after, accompanied by three policemen, Manuel returned to the scene where he immediately recognized and identified Marquez from among several people present as the one who had taken his wallet. Marquez was taken to the police station where, after questioning, he admitted his guilt to police officer Vicente Bautista and signed an extrajudicial confession (Exhibit A). He stated he did not know the name of his companion, having only recently met him. The individual with the revolver had not been apprehended at the time of the filing of the complaint.
At trial, Marquez denied the accusation. He testified that early on the morning in question, while waiting outside a toilet, he saw a man (Manuel) running, followed by others with pistols (policemen). These men searched the area and, upon Manuel’s indication, approached him, ordered him to raise his arms, and searched his body but found nothing. He was then taken to the police station where he was allegedly tortured into signing the confession, claiming he was dizzy and resigned to signing when he did. No witness corroborated his testimony.

ISSUE

The primary issue is one of credibility of evidence. A specific legal issue is also raised: whether the conviction based on the accused’s extrajudicial confession is valid under Article 96, Rule 123 of the Rules of Court, which requires such a confession to be corroborated by proof of the corpus delicti.

RULING

The Supreme Court affirmed the judgment of the Court of First Instance of Manila convicting Felix Marquez of robbery with intimidation.
1. On Credibility: The Court found the prosecution’s evidence sufficient for conviction. It gave credence to the testimony of the victim, Emeterio Manuel, who positively identified Marquez despite not knowing him beforehand. The Court found it believable that, during the brief robbery, the victim had the opportunity to fix his attention on the assailant’s features, noting that in such psychological crises, a victim’s senses and memory can become unusually acute. The Court also found Manuel’s immediate and certain identification of Marquez among several people to be credible. Regarding the alleged torture, the Court found no proof to support Marquez’s claim. Police officer Bautista, whose credibility was not seriously challenged, testified that Marquez had not been mistreated and was not dizzy when he confessed. Certain minor inconsistencies in Bautista’s testimony were deemed unimportant.
2. On the Extrajudicial Confession and Corpus Delicti: The defense invoked Article 96, Rule 123, arguing that the stolen money was not recovered (as the police found no money on Marquez during the search) and therefore the corpus delicti was not proven apart from the confession. The Court clarified this legal concept.
First, it explained that corpus delicti* does not mean the physical object of the crime (e.g., the stolen money). Essentially, it means that a specific crime has actually been committed by someone, comprising two elements: (a) a certain result has been produced, and (b) someone is criminally responsible.
* Second, the rule does not require proof of all elements of the crime independent of the confession. It merely requires some evidence, apart from the confession, tending to show that a crime has been committed. The Court cited its precedent in Pueblo vs. Bantagan, stating the rule is a precaution against convictions based on false confessions, not a requirement for proof sufficient for conviction independent of the confession.
In this case, the corpus delicti*—the fact that a robbery by intimidation was committed—was sufficiently established not only by the extrajudicial confession but also by the credible testimony of the victim, who identified Marquez as the perpetrator who took his wallet containing P20 while being threatened with a revolver.
The appealed judgment, which sentenced Marquez to an indeterminate penalty of 6 months of arresto mayor to 4 years of prision correccional, to indemnify P20, with subsidiary imprisonment in case of insolvency, and to pay costs, was confirmed in all respects.