G.R. NO.

206296 AUGUST 12, 2015

PEOPLE OF THE PHILIPPINES

VS.

RAMIL PENAFLOR y LAPUT

FACTS:

Estur, a COA Auditor, discovered in July 1913 rice stocks unaccounted for in the bodega
of the NFA. The stocks were under the account of Matas. Upon recommendation of Estur, COA State
Auditor IV, Betonio, who was the Provincial Manager of NFA, Lanao Del Norte, suspended Accused
Matas.

On August 21, 1993, at about 8:00 p.m., upon disembarkation of Betonio from the Ford Fierra
driven by Fajardo, he was stabbed and shoot in front of their apartment. Fajardo saw two men running
after the incident. He did not die immediately so he was able to whisper to his wife the name of Matas
and Ondo. The two men became the suspect of the police. However, in the course of the investigation,
they found out that the actual killer was Penaflor since he was the owner of the same knife which was
used to kill the victim. During the investigation, Penaflor admitted that he killed Betonio but he said that
he was hired and paid 15,000.00 pesos by Ondo. This confession was made at the prosecutor’s office..

After trial, the RTC acquitted accused Matas, Omilig, and Ondo, while it convicted accused-
appellant Peñaflor for the crime of murder for killing Betonio. The RTC admitted accused-appellant
Peñaflor’s extrajudicial confessions because they were not taken under duress or intimidation as the
extrajudicial confessions were conducted at the Prosecutor’s Office and not in a police station, and in
the presence of his relatives.

ISSUE:

Whether or Not the acquittal of Matas, Omilig, and Ondo by the RTC, correct, on the grounds
that the CORPUS DELICTI of the case was not proven, despite the confession of Ramil Penaflor that he
was only hired to kill Betonio

RULING:

Yes the decision of the RTC is correct, because the prosecution was only able to present physical
evidence, corroborated by several witnesses’ testimonies directly pointing to Ramil Penaflor, not Matas,
Omilig, and Ondo.

The prosecution presented the Death Certificate of Betonio and the Post-Mortem Examination
Report on the cadaver of Betonio, conducted by Dr. Villarin, who identified that the knife presented to
him during his examination as witness, was the same knife he removed from Betonio’s cadaver during
the post-mortem examination — the same knife which turned out to be owned by accused-appellant
Peñaflor. These pieces of evidence were further corroborated by testimonial evidence from Vicenta and
Fajardo, who all attested to the fact of murder of Betonio, committed by accused-appellant Peñaflor.
PRINCIPLE:

CORPUS DELICTI - Is the body, foundation or substance of the crime. It refers to the fact of the
commission of the crime, not to the physical body of the deceased. Because, corpus delicti may be
proven by circumstantial evidence, it is not necessary for the prosecution to present direct evidence to
prove the corpus delicti. Nevertheless, the prosecution must present the following elements: (a) that a
certain result or fact has been established; (b) that some person is criminally responsible for it.