Scribd Logo
Upload

Welcome to Scribd!

  • 93 views

    People vs. Anabe

    Uploaded by

    Andrew Ambray
    The Supreme Court of the Philippines overturned the conviction of Feliciano Anabe for robbery with homicide and destructive arson. [1] The sole testimony from the state witness Felicita was not sufficient to convict Anabe as it was not corroborated as required. [2] Felicita was not an eyewitness and her testimony constituted circumstantial rather than direct evidence. [3] The Court found Anabe guilty only of qualified theft, but not homicide or arson, as the evidence did not sufficiently prove his commission of violence or that the arson was intended to destroy evidence.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd

    People vs. Anabe

    Uploaded by

    Andrew Ambray
    93 views2 pages
    The Supreme Court of the Philippines overturned the conviction of Feliciano Anabe for robbery with homicide and destructive arson. [1] The sole testimony from the state witness Felicita was not sufficient to convict Anabe as it was not corroborated as required. [2] Felicita was not an eyewitness and her testimony constituted circumstantial rather than direct evidence. [3] The Court found Anabe guilty only of qualified theft, but not homicide or arson, as the evidence did not sufficiently prove his commission of violence or that the arson was intended to destroy evidence.

    Original Title

    7. People vs. Anabe

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF, TXT or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    The Supreme Court of the Philippines overturned the conviction of Feliciano Anabe for robbery with homicide and destructive arson. [1] The sole testimony from the state witness Felicita was not sufficient to convict Anabe as it was not corroborated as required. [2] Felicita was not an eyewitness and her testimony constituted circumstantial rather than direct evidence. [3] The Court found Anabe guilty only of qualified theft, but not homicide or arson, as the evidence did not sufficiently prove his commission of violence or that the arson was intended to destroy evidence.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    93 views2 pages

    People vs. Anabe

    Uploaded by

    Andrew Ambray
    The Supreme Court of the Philippines overturned the conviction of Feliciano Anabe for robbery with homicide and destructive arson. [1] The sole testimony from the state witness Felicita was not sufficient to convict Anabe as it was not corroborated as required. [2] Felicita was not an eyewitness and her testimony constituted circumstantial rather than direct evidence. [3] The Court found Anabe guilty only of qualified theft, but not homicide or arson, as the evidence did not sufficiently prove his commission of violence or that the arson was intended to destroy evidence.

    Copyright:

    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    You are on page 1of 2

    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.

    You might also like