(1) Petitioner was found guilty of smuggling 305 cases of untaxed cigarettes. (2) The Court affirmed the conviction, finding that the prosecution had sufficiently proven the corpus delicti or body of the crime through witness testimony and a customs receipt, even without presenting the physical cigarettes. (3) The Court upheld the lower courts' findings, noting public officers are presumed to have properly performed their duties and factual findings must be upheld absent errors.
(1) Petitioner was found guilty of smuggling 305 cases of untaxed cigarettes. (2) The Court affirmed the conviction, finding that the prosecution had sufficiently proven the corpus delicti or body of the crime through witness testimony and a customs receipt, even without presenting the physical cigarettes. (3) The Court upheld the lower courts' findings, noting public officers are presumed to have properly performed their duties and factual findings must be upheld absent errors.
(1) Petitioner was found guilty of smuggling 305 cases of untaxed cigarettes. (2) The Court affirmed the conviction, finding that the prosecution had sufficiently proven the corpus delicti or body of the crime through witness testimony and a customs receipt, even without presenting the physical cigarettes. (3) The Court upheld the lower courts' findings, noting public officers are presumed to have properly performed their duties and factual findings must be upheld absent errors.
(1) Petitioner was found guilty of smuggling 305 cases of untaxed cigarettes. (2) The Court affirmed the conviction, finding that the prosecution had sufficiently proven the corpus delicti or body of the crime through witness testimony and a customs receipt, even without presenting the physical cigarettes. (3) The Court upheld the lower courts' findings, noting public officers are presumed to have properly performed their duties and factual findings must be upheld absent errors.
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[G.R. No. 146481.
April 30, 2003] ISSUE:
ARTURO G. RIMORIN SR., petitioner, vs. PEOPLE OF THE WON petitioner guilty of smuggling. YES PHILIPPINES, respondent. HELD / RATIO: Digest by RJARuiz WHEREFORE, the Petition is DENIED, and the assailed Decision AFFIRMED. FACTS: Petitioner was charged with smuggling under the Tariff and Customs Corpus delicti refers to the fact of the commission of the crime Code for the fraudulent importation of three hundred five (305) cases of charged[15] or to the body or substance of the crime. [16]In its legal sense, assorted brands of blue seal cigarettes valued at P513,663.47. it does not refer to the ransom money in the crime of kidnapping for ransom[17] or to the body of the person murdered.[18] Hence, to prove Petitioner pleaded not guilty when arraigned. 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 The prosecution’s version of facts is as follows: building has been burned; and (2) a particular person is criminally On October 1979, Col. Panfilo Lacson, then Chief of the Metrocom responsible for the act.[19] Intelligence and Security Group (MISG), received information that groups were engaged in smuggling activities in Manila. He Since the corpus delicti is the fact of the commission of the crime, even a fielded three surveillance teams along Roxas Boulevard to watch single witness uncorroborated testimony, if credible, may suffice to out for a cargo truck with Plate No. T-SY-167 bound for prove it and warrant a conviction therefor. [20] Corpus delicti may even be Malabon. At around 4:00 oclock that morning, a green cargo established by circumstantial evidence.[21] truck with Plate No. T-SY-167 came out escorted by a Toyota Corona car with 4 men on board. The cargo truck was Both the RTC and the CA ruled that the corpus delicti had been intercepted. Col. Lacson noticed that the Toyota car suddenly competently established by respondents evidence, which consisted of made a sharp U-turn. Lacson gave chase which lasted for less the testimonies of credible witnesses and the Custody Receipt [22] issued than 5 minutes. Lacson and his men searched the car and they by the Bureau of Customs for the confiscated goods. found several firearms. Petitioner was then arrested. When the cargo truck was searched, 305 cases of blue seal or untaxed cigarettes were found. Col. Panfilo Lacson’s testimony on the apprehension of petitioner and on the seizure of the blue seal cigarettes was clear and straightforward. For his defense, petitioner insists that he was merely framed up. So, too, did Gregorio Abrigo -- customs warehouse storekeeper of the Bureau -- categorically testify[25] that the MISG had turned over to him The RTC and CA found petitioner guilty. the seized blue seal cigarettes, for which he issued a Custody Receipt dated October 15, 1979. Petitioner argues that he cannot be convicted of smuggling under the Tariff and Customs Code, because respondent failed to present the We find no reason to depart from the oft repeated doctrine of giving seized contraband cigarettes in court. Equating the actual physical credence to the narration of prosecution witnesses, especially when they evidence -- the 305 cases of blue seal cigarettes -- with the corpus are public officers who are presumed to have performed their duties in a delicti, he urges the SC to rule that the failure to present it was fatal to regular manner.[26] Moreover, findings of fact of lower courts are binding respondents cause. on this Court, absent any showing that they overlooked or misinterpreted facts or circumstances of weight and substance.