People of the Philippines vs.

Feliciano Anabe y Capillan

G.R. No. 179033. September 6, 2010.
DECISION
Carpio Morales, J.
DOCTRINE:
Sec. 17, Rule 119 of the Rules of Court require that the testimony of the
state witness must be corroborated in its material points to merit full credence.
The exception to corroboration is when the state witness is an
eyewitness (direct evidence), and his testimony is shown to be sincere in itself
because it is given unhesitatingly and in a straightforward manner and full of
details which, by their nature, could not have been the result of deliberate
afterthought.
FACTS:
In two separate informations filed with the RTC of Quezon City, Feliciano
Anabe (appellant) and one Felicita Generalao, in conspiracy with another
person, were charged with robbery with homicide and destructive arson. When
arraigned, both pleaded not guilty.
Felicita, who turned state witness, gave testimony that they were house
helpers of Chan and when Chan departed abroad, Chan’s brother-in-law Uy
stayed with Chan’s two-storey house. At around 8:00 pm of December 31,
1997, appellant instructed Felicita and Conrada to repair their room while he
sat beside Uy. After about an hour, Conrada went to the dining room and saw
appellant holding a knife. As Felicita fallowed, she saw the dead body of Uy
lying on the floor covered with a mat.
Appellant at once instructed Felicita and Conrada to leave the house;
then they hailed a taxicab of which the three of them boarded after he had
gone back to the house to set it on fire. They headed for a pier in Tondo and
boarded a boat that brought them to Masbate where they stayed in appellant’s
house for a week. On Felicita’s request, appellant brought her to her province
in Butuan.
The trial court rendered a decision convicting the appellant as charged
– robbery with homicide and destructive arson.
ISSUE:
 Whether or not the testimony given by the state witness in this case is
sufficient to convict the accused of the crime charged (robbery with homicide
and destructive arson).
RULING:
NO. The fact that appellant committed the felonious taking does not
mean that he also committed the violence, even assuming that both occurred
on the same occasion. The allegation that appellant committed violence on Uy
must be proved beyond reasonable doubt.
Fecilita’s testimony regarding appellant’s confession was not
corroborated by other evidence of the prosecution. The only other evidence
purportedly linking appellant to the commission of violence is the bloodstained
kitchen knife (allegedly seen by Conrada being held by appellant; seen by
Felicita on the table; and recovered by the police at the back of the house).
There is lack of proof that he was the only person who held the knife at the
crime scene.
A state witness cannot simply allege everything left unproved and
automatically produce a conviction of the crime charged against the remaining
accused. Corroboration of the account of the state witness is key. Sec. 17,
Rule 119 of the Rules require that the testimony to be given can be
substantially corroborated in its material points.
The exception to the general rule requiring corroboration is that the
uncorroborated testimony may be sufficient when it is shown to be sincere in
itself because it is given unhesitatingly and in a straightforward manner and
full of details which, by their nature, could not have been the result of
deliberate afterthought. This exception applies only if the state witness is an
eyewitness as this would constitute direct evidence as contemplated by Sec.
17, Rule 119.
In this case, the state witness is not an eyewitness, the testimony
partakes of the nature of circumstantial evidence. Hence, the rule on
circumstantial evidence applies and if left uncorroborated does not suffice.
The accused is guilty of only qualified theft (violence not proven and he
was a house helper where his employers reposed trust and confidence in him).
With respect to destructive arson, the burning of the house of Chan cannot be
for the purpose of concealing or destroying evidence. The authorship was not
proven as the testimony of Felicita was uncorroborated.