RIMORIN vs. PEOPLE,
GR 146481, April 30, 2003
X x x.
First Issue: Corpus Delicti Established by Other Evidence
Petitioner argues that he cannot be convicted of smuggling
under the Tariff and Customs Code, because respondent failed to present the
seized contraband cigarettes in court.
Equating the actual physical evidence -- the 305 cases of blue seal
cigarettes -- with the corpus delicti,
he urges this Court to rule that the failure to present it was fatal to
respondent’s cause.
We disagree. The Court, on several occasions, has
explained that corpus delicti refers to the fact of the commission of the crime
charged[1]
or to the body or substance of the crime.[2] In
its legal sense, it does not refer to the ransom money in the crime of
kidnapping for ransom[3]
or to the body of the person murdered.[4]
Hence, to prove the corpus delicti,
it is sufficient for the prosecution to be able show that (1) a certain fact
has been proven -- say, a person has died or a building has been burned; and
(2) a particular person is criminally responsible for the act.[5]
Since the corpus
delicti is the fact of the commission of the crime, this Court has ruled
that even a single witness’ uncorroborated testimony, if credible, may suffice
to prove it and warrant a conviction therefor.[6] Corpus delicti may even be established
by circumstantial evidence.[7]
Both the RTC and the CA ruled that the corpus delicti had been competently established by respondent’s
evidence, which consisted of the testimonies of credible witnesses and the
Custody Receipt[8]
issued by the Bureau of Customs for the confiscated goods.
Col. Panfilo Lacson’s testimony on the apprehension of
petitioner and on the seizure of the blue seal cigarettes was clear and
straightforward. X x x.
X x x.
We find no reason to depart from the oft repeated doctrine
of giving credence to the narration of prosecution witnesses, especially when
they are public officers who are presumed to have performed their duties in a
regular manner.[9]
Moreover, it is well-settled that findings of fact of lower
courts are binding on this Court, absent any showing that they overlooked or
misinterpreted facts or circumstances of weight and substance.[10]
This doctrine applies particularly to this case in which the RTC’s findings, as
far as petitioner is concerned, were affirmed by the appellate court.
X x x."
[1] People v. Mittu, 333 SCRA 121, June
8, 2000.
[2] People v. Oliva, 341 SCRA 78,
September 26, 2000; citing Tan v. People,
313 SCRA 220, August 26, 1999.
[3] People v. Mittu, supra.
[4]
People v. Roluna, 231 SCRA 446, March
24, 1994; citing People v. Sasota, 91 Phil. 111, April 18, 1952.
[5] People v. Boco, 38 Phil. 341, June
23, 1999; citing People v. Cabodoc,
331 Phil. 491, October 15, 1996.
[6] People v. Oliva, supra, p. 87; People v. Gutierrez, 258 SCRA 72, July
5, 1996.
[7] People v. Roluna, supra; citing People v. Sasota, supra.
[8]
Records, Vol. II, p. 147.
[9] People v. Alegro, 275 SCRA 216, July
8, 1997.
[10] People v. Boco, supra; People v. Gaorana, 289 SCRA 652,
April 27, 1998; People v. Oliano, 287 SCRA 158,
March 6, 1998; People v. Bahatan, 285 SCRA 282,
January 28, 1998.
