“The corpus delicti in arson is not merely the burning of the house, but the fact that it was burned by the willful act of some person criminally responsible for this act”
Corpus delicti is a Latin phrase that means “body of the crime.” It is the objective proof that the crime has been committed (Barron’s Law Dictionary).
It is sometimes mistakenly thought of as the body of a victim of homicide, but it is differently applied in courts.
In People v. Torres et al., the accused contended that the evidence is insufficient for his conviction since the weapons used in the stabbing of Espino, the victim, were not presented.
In other words, he asserted that it was improper to convict him because the “corpus delicti” [weapons] had not been established.
However, corpus delicti “does not refer to the ransom money in the crime of kidnapping for ransom or to the body of the person murdered or, in this case, the weapons used in the commission of robbery with homicide” (G.R. No. 189850, September 22, 2014).
Since the corpus delicti is the fact of the commission of the crime, the Court has ruled that even a single witness’ uncorroborated testimony, if credible, may suffice to prove it and warrant a conviction of the accused.
Corpus delicti may even be established by circumstantial evidence (People v. Torres, et al., G.R. No. 189850, September 22, 2014).
Where proof of corpus delicti consists of circumstantial evidence, the circumstances proven should constitute an unbroken chain which leads to one fair and reasonable conclusion; which in turn points to the defendant, and to the exclusion of all others, as the guilty person (Evidence, Francisco citing People v. Ong Chiat Lay, 60 Phil. 788).
In Torres, the corpus delicti was established by the evidence on record. The prosecution eyewitnesses testified that the appellant and his cohorts used knives to perpetrate the crime.
Their testimonies on the existence and use of weapons in committing the offense was supported by the medical findings of Dr. Salen who conducted the post-mortem examination (G.R. No. 189850, September 22, 2014).
Corpus delicti is essentially made up of two elements: (a) that a certain result has been produced (for example, a man has died or a building has been burned); and (b) that some person is criminally responsible for the act (Evidence, Francisco).
The corpus delicti in arson is not merely the burning of the house, but the fact that it was burned by the willful act of some person criminally responsible for this act.
This act cannot be accidental, nor can it be a consequence of natural events (Evidence, Francisco citing 20 Am. Jur. 156).
Similarly, in the crime of abortion, corpus delicti consists of the pregnancy of the woman, and that the miscarriage was brought about by the criminal act of another.
In criminal adultery, it consists of the alleged prohibited intercourse between a man and a woman (Evidence, Francisco citing 20 Am. Jur. 156).
In Tan v. People, complainant Rosita Lim (Lim) was engaged in the business of manufacturing propellers or spare parts for boats. Complainant Lim noticed that some of the welding rods, propellers and boat spare parts worth P48,000.00 were missing (G.R. No. 134298, August 26, 1999).
Manuelito Mendez, a former employee, admitted that he and his companion Gaudencio Dayop stole some spare boat parts from the complainant’s warehouse; Mendez later asked for complainant’s forgiveness.
He pointed to Ramon C. Tan as the one who bought the stolen items and paid the amount of P13,000.00 (G.R. No. 134298, August 26, 1999).
Ramon Tan was charged and prosecuted for violation of Presidential Decree No. 1612 (Anti-Fencing Law), for acquiring several spare parts and items, all belonging to Complainant Lim, for fishing boats, which he knew or should have known were derived from the proceeds of the crime of theft (G.R. No. 134298, August 26, 1999).
In theft, corpus delicti has two elements, namely: (1) that the property was lost by the owner, and that (2) it was lost by felonious taking. In this case, the theft was not proved because the complainant did not complain to the public authorities of the felonious taking of her property (G.R. No. 134298, August 26, 1999).
Furthermore, Mendez confessed to stealing the articles from the complainant and was forgiven by the latter. Such a confession is insufficient to convict without evidence of corpus delicti or the commission of the crime.
Besides, an admission or confession may be given in evidence only against the person making the admission or confession (G.R. No. 134298. August 26, 1999).
An extrajudicial confession made by the defendant or accused does not warrant a conviction unless corroborated by independent evidence of corpus delicti (Section 3, Rule 133, Rules on Evidence). This means that there must be some evidence tending to show the commission of the crime apart from the extrajudicial confession (Evidence, Francisco).
In People v. Relato, the Court explained that in a prosecution of the sale and possession of dangerous drugs prohibited under R.A. No. 9165, the State not only carries the heavy burden of proving the elements of the offense, but also bears the obligation to prove the corpus delicti, failing in which the State will not discharge its basic duty of proving the guilt of the accused beyond reasonable doubt (cited in Tolentino v. People, G.R. No. 227217, February 12, 2020).
It is settled that the State does not establish the corpus delicti when the prohibited substance that is the subject of the prosecution is missing or when substantial gaps in the chain of custody of the prohibited substance raise doubts about the authenticity of the prohibited substance presented as evidence in court (Tolentino v. People, G.R. No. 227217, February 12, 2020 citing People v. Relato).
In Rimorin v. People, Rimorin argued that he cannot be convicted of smuggling under the Tariff and Customs Code, because the People failed to present the seized contraband cigarettes in court.
Equating the actual physical evidence of 305 cases of blue seal cigarettes to the corpus delicti, he urges the Supreme Court to rule that the failure to present it was fatal to the People’s cause (G. R. No. 146481, April 30, 2003).
The Supreme Court disagreed with Rimorin. On several occasions it has explained that corpus delicti refers to the fact of the commission of the crime charged or to the body or substance of the crime.
Both the RTC and the CA ruled that the corpus delicti had been competently established by the People’s evidence, which consisted of the testimonies of credible witnesses and the Custody Receipt issued by the Bureau of Customs for the confiscated goods (G. R. No. 146481, April 30, 2003).