People Vs Ricky Quimzon G.R. No. 133541

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People vs Ricky Quimzon

G.R. No. 133541


April 14, 2004
Topic: Corpus Delicti
Case: Appeal the decision of a lower court finding Ricky Quimzon guilty beyond reasonable
doubt for the crime of murder.
Parties involved:
 Ricky Quimzon – accused/appellant
 Marlo Casiong – Victim
 Emoly Casiong (Sister), Rommel Redona - Witnesses
Facts:
 Ricky Quimzon and three oher persons, namely Salvacion Lascarom, Canoto Cabero and
Edgardo Detona were charged with the crime of murder
 The above-named accused, conspiring, confederating and helping one another with
treachery and abuse of superior strength, with intent to kill, did then and there willfully,
unlawfully, and feloniuosly attack, assault, strike, stab and wound one Marlo Casiong
with short bolos locally known as “pisao” which accused provided themselves for the
purpose, thereby hitting and inflicting upon the said Marlo Casiong with fatal wounds on
the different parts of his body which caused his death shortly thereafter.
Issue:
 IT IS SUBMITTED BY THE APPELLANT THAT THE REGIONAL TRIAL COURT
OF BURAUEN, LEYTE ERRED IN FINDING THE ACCUSED GUILTY OF THE
CRIME OF MURDER WITHOUT A CORPUS DELICTI.
 IT IS SUBMITTED BY THE APPELLANT THAT THE REGIONAL TRIAL COURT
OF BURAUEN, LEYTE ERRED IN GIVING CREDENCE TO THE TESTIMONY OF
EMOLYN CASIONG THE LONE PROSECUTION EYE WITNESS, LEADING TO
THE CONVICTION OF APPELLANT ON THE CRIME CHARGED IN THE ABOVE
ENTITLED CASE.
Held:
WHEREFORE, the decision of the Regional Trial Court of Tacloban City (Branch 15) is
AFFIRMED with MODIFICATIONS. Appellant Ricky Quimzon is found GUILTY beyond
reasonable doubt of the crime of MURDER and after applying The Indeterminate Sentence Law,
and there being no modifying circumstance, he is sentenced to suffer imprisonment, from eight
(8) years and one (1) day of prision mayor as MINIMUM up to fourteen (14) years and ten (10)
months of reclusion temporal as MAXIMUM. He is ordered to pay Erlinda Casiong, the mother
of the deceased Marlo Casiong, the amounts of ₱50,000.00 as civil indemnity for the victim’s
death; ₱25,000.00 as temperate damages; and ₱50,000.00 as moral damages.
The Court took in consideration that the accused was a minor when the crime was committed and
reduced the sentence from reclusion perpetua to prison mayor.

Doctrines:

Corpus delicti is defined as the body, foundation or substance upon which a crime has been
committed, e.g. the corpse of a murdered man. It refers to the fact that a crime has been actually
committed. Corpus delicti does not refer to the autopsy report evidencing the nature of the
wounds sustained by the victim nor the testimony of the physician who conducted the autopsy or
medical examination. It is made up of two elements: (a) that a certain result has been proved, for
example, a man has died and (b) that some person is criminally responsible for the act.

Proof of corpus delicti is indispensable in prosecutions for felonies and offenses. While the
autopsy report of a medico legal expert in cases of murder or homicide is preferably accepted to
show the extent of the injuries suffered by the victim, it is not the only competent evidence to
prove the injuries and the fact of death. It may be proved by the testimonies of credible
witnesses. Even a single witness’ uncorroborated testimony, if credible, may suffice to prove it
and warrant a conviction therefor.

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