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JOSE ANGELES v. CA

FACTS:

Petitioner Jose Angeles, Jr., together with Teresita Uy-Abubakar, Florante Sapitula alias "Bong", Dedardo Deles alias "Boy", Antonio Suganob alias "Tony", Andres Tello alias "Boy Tello", and Boy Apostol, were charged with Robbery for allegedly conspiring to steal nine hundred seventy-three (973) cartons of assorted products of the Philippine Refining Company worth P384,384.81. Dedardo Deles and Boy Apostol remained at large while the rest of the accused pleaded not guilty and the case proceeded to trial.

According to the Court of Appeals, on December 17, 1984, a Red Ball Express truck of Ansuico, Inc., driven by Gaudencio Juyo, was flagged down by Andres Tello, another driver of Ansuico, Inc. Tello, along with Dedardo Deles and Florante Sapitula, requested to hitch a ride to Digos, Davao del Sur. The driver, Juyo, consented and allowed them to ride inside the driver's compartment. However, while in Sta. Cruz, Davao del Sur, Deles and Sapitula brandished a caliber thirty-eight pistol and a grenade, declaring a hold-up. They stated that they were NPAs and needed the goods for the mountains. Juyo took over driving the truck and upon their arrival in Davao City, the goods were unloaded in a house owned by Cesar Maglalang. The next day, Juyo, Oribado, and Deles drove the truck back to Davao del Sur, and Deles instructed them to report the hold-up to the police. Juyo and Oribado reported the robbery, and later, the PC investigators questioned Andres Tello, who implicated Sapitula and Suganob, and subsequently, Deles, Angeles, Jr., and Abubakar. Andres Tello eventually became a state witness, and his testimony, along with that of Juyo and Oribado, solidified the case for the prosecution.

ISSUES:

  1. Whether or not petitioner Jose Angeles, Jr. may be convicted on the basis solely of the uncorroborated and unsubstantial testimony of the discharged witness Andres Tello.

  2. Whether or not the role of Jose Angeles, Jr. as principal in the alleged conspiracy has been established.

  3. Whether or not the Court of Appeals scrutinized the records of the case and whether or not the guilt of petitioner was proved beyond reasonable doubt.

  4. Whether or not the petitioner's participation in the conspiracy has been established.

  5. Whether or not the petitioner's guilt has been proved beyond reasonable doubt.

RULING:

  1. The testimony of a single witness, free from any sign of impropriety or falsehood, is sufficient for conviction, even if uncorroborated. In this case, there is nothing in the records to indicate that the discharged witness, Andres Tello, falsified the truth or that his observation was inaccurate. Thus, his uncorroborated testimony is considered sufficient to sustain the conviction.

  2. The role of petitioner Jose Angeles, Jr. as the principal in the alleged conspiracy was established through the testimony of the discharged witness, as well as other evidence presented during the trial.

  3. The Court of Appeals properly scrutinized the records of the case and found that the guilt of petitioner was proved beyond reasonable doubt. The trial court's decision was affirmed, with only a modification in the penalty imposed on petitioner.

  4. The court held that the petitioner's participation in the conspiracy has been convincingly proven by the testimony of the state witness. The petitioner was the one who discussed and planned the robbery and the hijacked goods were unloaded in the house that he rented and later transferred to a company that he owns. Therefore, his role as a principal in the alleged conspiracy has been established.

  5. As for the second issue, the court ruled that the petitioner's guilt has been proved beyond reasonable doubt. The testimony of the state witness, which was corroborated by other witnesses, directly linked the petitioner to the crime as charged. The court also noted that conspiracy can be deduced from the mode and manner of the commission of the offense and the acts of the accused before, during, and after the crime. In this case, the prior planning meetings held at the petitioner's house and his clear orchestration of the crime indicate a joint purpose and community of interest.

PRINCIPLES:

  • The testimony of a single witness, free from any sign of impropriety or falsehood, is sufficient for conviction, even if uncorroborated, unless the law expressly prescribes a minimum number of witnesses.

  • Corroborative evidence is deemed necessary only when there are reasons to warrant the suspicion that the witness falsified the truth or that their observation had been inaccurate.

  • The role of a principal in a conspiracy can be established through testimonial and other evidence presented during the trial.

  • Findings of the trial court with respect to the credibility of witnesses and their testimonies are entitled to great respect and even finality unless they are arbitrary or facts and circumstances of weight and influence have been overlooked, misunderstood, or misapplied by the trial judge.

  • Conspiracy may be established through direct proof or deduced from the mode and manner of the commission of the offense and the acts of the accused before, during, and after the crime, indicating a joint purpose, concert of action, and community of interest.