G.R. No. L-6059, March 3, 1911
THE UNITED STATES, plaintiff-appellee, vs. ARCADIO BERNALES, defendant-appellant.

FACTS

Arcadio Bernales was one of nine persons tried for the crime of robo en cuadrilla (robbery in band). On the night of April 13, 1909, four Chinese merchants traveling by boat (baroto) from Pontevedra to Capiz were assaulted and robbed of P2,150 by three defendants (Anastacio Bernales, Candelario Budiao, and Guillermo Bula), who acted in concert with their boatmen (boteros). Of the stolen amount, P791.15 was recovered. The prosecution alleged that Arcadio Bernales was the inducer of the crime and received the greater part of the booty. The main evidence against him came from his co-accused and accomplice, Guillermo Bula, who testified that Bernales planned the robbery, received the stolen trunk, took all the paper money, and divided the silver among the participants. This testimony was corroborated by the recovery of part of the stolen money (P308.05) buried under a house where Bernales was seen acting suspiciously. Bernales denied any involvement, and his denial was supported by two other convicted co-accused who did not appeal.

ISSUE

Whether the testimony of an accomplice (Guillermo Bula), corroborated by circumstantial evidence, is sufficient to sustain Bernales’ conviction for robo en cuadrilla beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. While the testimony of an accomplice must be received with caution, it can be the basis for a conviction if sufficiently corroborated. Here, the testimony of Guillermo Bula was richly corroborated by other witnesses and circumstances, including the recovery of part of the stolen money buried in a place linked to Bernales. The totality of evidence left no reasonable doubt as to Bernales’ guilt as an author of the crime. The penalty of ten years’ imprisonment and restitution imposed by the trial court was within the limits prescribed by law and was therefore affirmed.