People v. Nazario
REITERATIONFacts
The Antecedents: The accused-appellants, Alfonso Nazario and Angel Biglangawa, were convicted by the Court of First Instance of Manila for the crime of robbery. They were sentenced to an indeterminate penalty and ordered to indemnify the offended party, Juliet Dilli, in the amount of P200. The alleged crime occurred on February 10, 1946, at 70 Lamayan Street, Sta. Ana, Manila. Procedural History: The accused-appellants appealed their conviction to the Supreme Court, assigning two errors: (1) the admission of alleged extra-judicial confessions (Exhibits A and B) without corroborating evidence of the corpus delicti, and (2) the evaluation of the stolen property at P200 without sufficient evidence. The Petition: The appellants prayed for their acquittal.
Issue(s)
Whether the alleged extra-judicial confessions were sufficient grounds for conviction without corroborating evidence of the corpus delicti. Whether there was sufficient evidence to prove the corpus delicti of the crime of robbery.
Ruling
The Supreme Court reversed the judgment of the trial court, acquitted the accused-appellants, and declared the costs de oficio.
Ratio Decidendi
On the sufficiency of extra-judicial confessions without corroboration: The Court held that an extra-judicial confession, by itself, is not a sufficient ground for conviction unless corroborated by evidence of the corpus delicti, as provided by Rule 123, Section 96 of the Rules of Court. The Court noted that the offended party, Juliet Dilli, did not testify at the trial. The testimony of a police witness regarding Dilli's report of the robbery and the alleged stolen items was considered hearsay evidence. Furthermore, no other witness with personal knowledge testified to prove any element of the crime of robbery. Therefore, the alleged confessions, Exhibits A and B, were legally insufficient for conviction under these circumstances. On the failure of proof of the corpus delicti: The Court found a complete failure of proof, independent of the alleged confessions, that the crime of robbery had been committed. The witness Rebollido had no personal knowledge of the alleged incident or the loss of property. The neighbor who allegedly saw one of the accused descending the stairs did not testify. Consequently, there was no independent evidence tending to show that a crime had actually been committed, which is a prerequisite for conviction based on an extra-judicial confession.
Main Doctrine
An extra-judicial confession, by itself, is insufficient for conviction unless corroborated by evidence of the corpus delicti.