Corpus delicti

1. Concept

“Corpus delicti” – refers to the fact of the commission of the crime charged or to the body or substance of the crime. (Rimorin, Sr. v. People, G.R. No. 146481, 30 April 2003)

In its legal sense, [corpus delicti] does not refer to the ransom money in the crime of kidnapping for ransom or to the body of the person murdered. (Ibid.)

Corpus delicti is the body, foundation or substance of a crime. It refers to the fact of the commission of the crime, not to the physical body of the deceased. (People v. Bacares, G.R. No. 243024, 23 June 2020)

2. Requisites

[T]o prove 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 building has been burned; and

2) A particular person is criminally responsible for the act. (Rimorin, Sr. v. People, supra.)

a. Proven fact

Since the corpus delicti is the fact of the commission of the crime, this Court has ruled that even a single witness’ uncorroborated testimony, if credible, may suffice to prove it and warrant a conviction therefor. Corpus delicti may even be established by circumstantial evidence. (Ibid.)

ZAPANTA v. PEOPLE, G.R. No. 170863, 20 March 2013

• The [accused] argues that his conviction was improper because the alleged stolen beams or corpus delicti had not been established. He asserts that the failure to present the alleged stolen beams in court was fatal to the prosecution’s cause.

• The [accused’s] argument fails to persuade us.

• In this case, the testimonial and documentary evidence on record fully established the corpus delicti. The positive testimonies of the prosecution witnesses, particularly Bernardo, Cano and Buen, stating that the [accused] directed them to unload the steel beams along Marcos Highway and Mabini Street on the pretext of a new Anmar project, were crucial to the [accused’s] conviction. The security logbook entry, delivery receipts and photographs proved the existence and the unloading of the steel beams to a different location other than the project site.

b. Particular person is responsible

That a particular person should be held criminally liable for the offense or act should be duly proven.

RIMORIN, SR. v. PEOPLE, G.R. No. 146481, 30 April 2003

• Both the RTC and the CA ruled that the corpus delicti had been competently established by respondent’s evidence, which consisted of the testimonies of credible witnesses and the Custody Receipt issued by the Bureau of Customs for the confiscated goods.

• Col. [P.] Lacson’s testimony on the apprehension of petitioner and on the seizure of the blue seal cigarettes was clear and straightforward.

• So, too, did [G.] Abrigo — customs warehouse storekeeper of the Bureau — categorically testify that the MISG had turned over to him the seized blue seal cigarettes, for which he issued a Custody Receipt dated October 15, 1979.

• We find no reason to depart from the oft repeated doctrine of giving credence to the narration of prosecution witnesses, especially when they are public officers who are presumed to have performed their duties in a regular manner.

3. Corpus delicti in offenses or crimes

There are requirements for corpus delicti to apply in certain offenses/crimes.

a. Dangerous drugs

In drug-related cases, the corpus delicti – the body of the offense – is the seized drugs themselves. (People v. Asaytuno, G.R. No. 245972, 02 December 2019)

The illegal drug itself constitutes the corpus delicti of the offense. Its existence must be proved beyond reasonable doubt. (People v. Ameril, G.R. No. 222192, 13 March 2019)

[I]n 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. It is settled that the State does not establish the corpus delicti when the prohibited substance subject of the prosecution is missing or when substantial gaps in the chain of custody of the prohibited substance raise grave doubts about the authenticity of the prohibited substance presented as evidence in court. Any gap renders the case for the State less than complete in terms of proving the guilt of the accused beyond reasonable doubt. (Tolentino v. People, G.R. No. 227217, 12 February 2020)

Law enforcers’ failure to strictly comply with the Comprehensive Dangerous Drugs Act’s chain of custody requirements engenders the prosecution’s failure to establish the corpus delicti in drug offenses. This is especially true for cases that involve miniscule amounts of dangerous drugs. When there is doubt on the identity and integrity of the corpus delicti, an accused’s acquittal must necessarily follow. (People v. Asaytuno, Jr., G.R. No. 245972, 02 December 2019)

PEOPLE v. MIRONDO, G.R. No. 210841, 14 October 2015

• In the prosecution of criminal cases involving drugs, it is firmly entrenched in our jurisprudence that the narcotic substance itself constitutes the corpus delicti, the body or substance of the crime, and the fact of its existence is a condition sine qua non to sustain a judgment of conviction. It is essential that the prosecution must prove with certitude that the narcotic substance confiscated from the suspect is the same drug offered in evidence before the court. As such, the presentation in court of the corpus delicti establishes the fact that a crime has actually been committed. Failure to introduce the subject narcotic substance as an exhibit during trial is, therefore, fatal to the prosecution’s cause.

b. Theft

In theft, corpus delicti has two elements, namely:

1) That the property was lost by the owner, and

2) That it was lost by felonious taking. (Tan v. People, G.R. No. 134298, 26 August 1999)

TAN v. PEOPLE, G.R. No. 134298, 26 August 1999

• In this case, the theft was not proved because complainant [R.] Lim did not complain to the public authorities of the felonious taking of her property. She sought out her former employee [M,] Mendez, who confessed that he stole certain articles from the warehouse of the complainant and sold them to petitioner. Such confession is insufficient to convict, without evidence of corpus delicti.

/Updated: January 14, 2023

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