Digest PP vs. PABALAN

Cumulative vs.
Corroborative Evidence
PEOPLE vs. PABALAN
FACTS:
Restituto Pabalan was found guilty of illegal recruitment in large scale and estafa based on
the testimonies of three complainants.
ISSUE:
Whether mere corroborative evidence would suffice to establish guilt beyond reasonable
doubt
RULING:
YES. The fact that no additional evidence was presented, aside from the testimony of
Garcia, will not militate against his credibility. Corroborative evidence is necessary only
when there are reasons to warrant the suspicion that the witness falsified the truth or that
his observations are incorrect. Complainant Garcia's straightforward and clear testimony
renders unnecessary the presentation of documents and other evidence to prove that
appellant was the one who engaged him to work abroad.
Neither will the failure of the prosecution to present Espino (alleged companion of Pabalan
in recruitment) diminish the credibility of Garcia. It has been held that the non-presentation
of certain witnesses by the prosecution is not a plausible defense and the matter of whom to
present as witnesses for the prosecution lies in the sound discretion of the prosecutor
handling the case. 22 Thus no adverse inference against the case of the People can be
deduced from the failure of the prosecution to present Espino. Besides, if the prosecution
had opted to present Espino, his testimony would merely be corroborative and can thus be
dispensed with.23
All the witnesses for the prosecution categorically testified that it was appellant who
promised them that he could arrange for and facilitate their employment abroad. We quote
with approval the conclusion of the lower court that the narration of the prosecution
witnesses Henry Luciano, June Barrera and Manuel Garcia are the more believable story.
Their testimonies appeared credible. There is no reason not to believe or discard their
testimonies. There is no sign that they testified falsely against the accused.
Denials of an accused cannot be given greater evidentiary weight than the positive
declarations of credible witnesses who testify on affirmative matters. Verily, the trial court
was correct in accepting the version of the prosecution witnesses as their statements are
positive and affirmative in nature. Their testimonies are more worthy of credit than the
uncorroborated31 and self-serving denials of appellant.
it also bears mention that the testimony of a single prosecution witness, where credible and
positive, is sufficient to prove beyond reasonable doubt the guilt of the accused.38 There is
no law which requires that the testimony of a single witness has to be corroborated, except
where expressly mandated in determining the value and credibility of evidence. Witnesses
are to be weighed, not numbered.
Page 1 of 2
Cumulative vs. Corroborative Evidence
PRINCIPLES:
Corroborative evidence is necessary only when there are reasons to warrant the
suspicion that the witness falsified the truth or that his observations are incorrect.—The
fact that no additional evidence was presented, aside from the testimony of Garcia, will
not militate against his credibility. Corroborative evidence is necessary only when there
are reasons to warrant the suspicion that the witness falsified the truth or that his
observations are incorrect. Complainant Garcia’s straightforward and clear testimony
renders unnecessary the presentation of documents and other evidence to prove that
appellant was the one who engaged him to work abroad.
The non-presentation of certain witnesses by the prosecution is not a plausible defense

and the matter of whom to present as witnesses for the prosecution lies in the sound
discretion of the prosecutor handling the case.—Neither will the failure of the
prosecution to present Espino diminish the credibility of Garcia. It has been held that
the non-presentation of certain witnesses by the prosecution is not a plausible defense
and the matter of whom to present as witnesses for the prosecution lies in the sound
discretion of the prosecutor handling the case. Thus no adverse inference against the
case of the People can be deduced from the failure of the prosecution to present
Espino. Besides, if the prosecution had opted to present Espino, his testimony would
merely be corroborative and can thus be dispensed with.
It is well-settled that minor discrepancies in the testimony of a prosecution witness do

not affect his credibility.—Appellant further attacks the credibility of Garcia by
theorizing that it was preposterous to buy the latter’s airplane ticket on March 29, 1993
when, according to his own testimony, he met appellant only on April 3, 1993. It is,
however, well settled that minor discrepancies in the testimony of a prosecution witness
do not affect his credibility.
The testimony of a single prosecution witness, where credible and positive, is sufficient
to prove beyond reasonable doubt the guilt of the accused.—He also avers that his
conviction in the second estafa case was without legal basis because there was no other
evidence, documentary or testimonial, establishing the crime of estafa except for the
testimony of Garcia. Although this contention has already been disposed of in the
discussions above, it also bears mention that the testimony of a single prosecution
witness, where credible and positive, is sufficient to prove beyond reasonable doubt the
guilt of the accused. There is no law which requires that the testimony of a single
witness has to be corroborated, except where expressly mandated in determining the
value and credibility of evidence. Witnesses are to be weighed, not numbered.
Denials of an accused cannot be given greater evidentiary weight than the positive
declarations of credible witnesses who testify on affirmative matters.—Denials of an
accused cannot be given greater evidentiary weight than the positive declarations of
credible witnesses who testify on affirmative matters. Verily, the trial court was correct
in accepting the version of the prosecution witnesses as their statements are positive
and affirmative in nature. Their testimonies are more worthy of credit than the
uncorroborated and self-serving denials of appellant.
Non-flight is not a conclusive proof of innocence because such inaction may be due to
several factors.—Appellant finally stresses that if indeed he was guilty of illegal
recruitment, he could have simply changed his residence to evade prosecution. This
argument is, unfortunately, purely hypothetical and clearly non sequitur. It cannot, by
itself, strengthen his credibility or weaken those of the prosecution’s witnesses. We
have already ruled that non-flight is not a conclusive proof of innocence because such
inaction may be due to several factors. People vs. Pabalan, 262 SCRA 574, G.R. No.
115350, G.R. Nos. 117819-21 September 30, 1996
Page 2 of 2

Digest PP vs. PABALAN

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Cumulative vs.

PEOPLE vs. PABALAN

The non-presentation of certain witnesses by the prosecution is not a plausible defense

It is well-settled that minor discrepancies in the testimony of a prosecution witness do

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