People v. Buada
REITERATIONFacts
The Antecedents: The accused was convicted of robbery for cutting through the wall of a dwelling and stealing a trunk containing money and property valued at P470.45. The stolen trunk was found the next day near the house. Procedural History: The complaint was initially filed against the appellant alone. A witness claimed to have seen the appellant and others armed and rifling the trunk, leading the fiscal to file a new complaint alleging robbery by an armed band. However, this witness was later shown to be hostile and their testimony improbable, leading the trial court to disregard it entirely and discharge other defendants. The accused was convicted based on other evidence as the sole perpetrator, not in a band and not armed. The Petition: The appellant contended that the trial court's finding of a witness being false should lead to the disregard of all government testimony under the maxim 'falsus in uno, falsus in omnibus'. He also argued that the sale of a stolen article is not possession and that possession of only one article is not proof of larceny of others.
Issue(s)
Whether the maxim "falsus in uno, falsus in omnibus" mandates the disregard of all government testimony when one witness is found to be false. Whether the sale of a stolen article constitutes possession. Whether the possession of only one stolen article is sufficient proof of the larceny of other stolen articles.
Ruling
The Supreme Court affirmed the conviction of the appellant, awarding a minimum sentence of one year of prision correccional.
Ratio Decidendi
On the maxim 'falsus in uno, falsus in omnibus': The Court held that there is no justification for the doctrine that if one witness is false, all witnesses are false. The maxim 'falsus in uno, falsus in omnibus' is applied only in rare cases where the false testimony is so material and has such a direct bearing on the case that it creates the impression that the witness is of a character that cannot be believed with any safety. The Court noted that this doctrine is often presented when there are minor inconsistencies or contradictions between witnesses, which do not warrant its application. The Court found no reason to apply this maxim in the present case, as the witness in question was found to be hostile and their testimony was disregarded by the trial court, and the conviction was based on other evidence. On the sale of a stolen article as possession: The Court clarified that the sale of a stolen article is as much an act of possession as treasuring the article on the person of the accused. The act of selling implies prior possession and control over the item. Therefore, the appellant's act of selling the stolen necklace was considered an exercise of possession. On possession of one article as proof of larceny of others: The Court affirmed the rule that the possession of a part of the stolen property warrants the inference that the accused stole all of it. This principle is based on the common experience that a person in possession of stolen goods is likely to be the thief of all the goods. The Court cited Corpus Juris to support this rule, stating that possession of a portion of the stolen property is sufficient to infer guilt for the entire theft.
Main Doctrine
The possession of a part of stolen property warrants the inference that the accused stole all of it. Furthermore, the maxim 'falsus in uno, falsus in omnibus' is applied only in rare cases where the false testimony is so material and has such a direct bearing on the case that it creates the impression that the witness is of a character that cannot be believed with any safety.