Damien Davon Benguche v. Commonwealth of Virginia

CourtCourt of Appeals of Virginia
DecidedOctober 9, 2012
Docket0688113
StatusUnpublished

This text of Damien Davon Benguche v. Commonwealth of Virginia (Damien Davon Benguche v. Commonwealth of Virginia) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Damien Davon Benguche v. Commonwealth of Virginia, (Va. Ct. App. 2012).

Opinion

COURT OF APPEALS OF VIRGINIA

Present: Judges Elder, Beales and Senior Judge Willis UNPUBLISHED

Argued at Salem, Virginia

DAMIEN DAVON BENGUCHE MEMORANDUM OPINION * BY v. Record No. 0688-11-3 JUDGE JERE M. H. WILLIS, JR. OCTOBER 9, 2012 COMMONWEALTH OF VIRGINIA

FROM THE CIRCUIT COURT OF FRANKLIN COUNTY William N. Alexander, II, Judge

Arthur J. Donaldson for appellant.

Benjamin H. Katz, Assistant Attorney General (Kenneth T. Cuccinelli, II, Attorney General, on brief), for appellee.

On appeal from his conviction of possession of a firearm after having been convicted of a

violent felony, in violation of Code § 18.2-308.2, Damien Davon Benguche contends that the

trial court erred in failing to dismiss the charge on the ground that the Commonwealth presented

insufficient corroborating evidence to prove the corpus delicti. 1 We affirm the judgment of the

trial court.

Background

“On appeal, ‘we review the evidence in the light most favorable to the Commonwealth,

granting to it all reasonable inferences fairly deducible therefrom.’” Archer v. Commonwealth, * Pursuant to Code § 17.1-413, this opinion is not designated for publication. 1 As Benguche presented no argument in support of a second assignment of error for which an appeal was awarded, that issue is waived on appeal. See Rule 5A:20(e) (requiring appellants to brief “the argument (including principles of law and authorities) relating to each assignment of error.” See also Wilson v. Commonwealth, 54 Va. App. 631, 638, 681 S.E.2d 74, 78 (2009) (“Pursuant to [Rule 5A:20], we have held that ‘[u]nsupported assertions of error do not merit appellate consideration.’” (quoting Jones v. Commonwealth, 51 Va. App. 730, 734, 660 S.E.2d 343, 345 (2008))). 26 Va. App. 1, 11, 492 S.E.2d 826, 831 (1997) (quoting Martin v. Commonwealth, 4 Va. App.

438, 443, 358 S.E.2d 415, 418 (1987)).

On June 27, 2010, a white SUV pulled in front of the vehicle in which Conservation

Officer Matthew Silicki was a passenger. Seconds later, Silicki saw an arm emerge from the

passenger side of the SUV, heard approximately five shots in rapid succession, and saw a muzzle

flash. Silicki could not discern whether the shots were fired from the front or rear passenger

side.

When Silicki’s partner activated the emergency lights and siren on their vehicle, the SUV

sped up. Silicki saw a handgun tossed from a passenger side window into a field. The SUV then

stopped. At that time, Benguche was seated in the backseat on the passenger side. Kenny

Edwards was in the driver’s seat, and Travis Edwards was sitting in the front passenger seat.

The handgun was recovered from the field into which it had been tossed. Its character is

not at issue in this appeal. Nor is it questioned or at issue that Benguche had previously been

convicted of a violent felony.

After the three men were arrested and incarcerated, Benguche apologized to Kenny

Edwards. Edwards testified that Benguche acknowledged the handgun was his and said that he,

Benguche, would “take responsibility for it.” Edwards also testified that Benguche assured him

that he, Edwards, would not go to jail. At trial, Benguche denied having this conversation with

Edwards. He said Edwards was lying.

Analysis

Benguche contends he cannot be convicted upon his confession to Kenny Edwards,

because the Commonwealth failed to present sufficient corroborating evidence to prove the

corpus delicti of the offense.

-2- It is well settled in Virginia that “‘the corpus delicti cannot be established by the extra

judicial confession of an accused uncorroborated by other evidence.’” Phillips v.

Commonwealth, 202 Va. 207, 211, 116 S.E.2d 282, 285 (1960) (quoting Wheeler v.

Commonwealth, 192 Va. 665, 669, 66 S.E.2d 605, 607 (1951)). To obtain a conviction upon the

accused’s extra-judicial confession, the evidence “must corroborate the elements of the corpus

delicti.” Roach v. Commonwealth, 251 Va. 324, 344, 468 S.E.2d 98, 110 (1996), overruled in

part on other grounds by Morrisette v. Warden of the Sussex I State Prison, 270 Va. 188, 613

S.E.2d 551 (2005). “‘[T]he confession must be corroborated in a material and substantial

manner by evidence aliunde of the corpus delicti.’” Phillips, 202 Va. at 211, 116 S.E.2d at 284

(quoting 7 M.J., Evidence, § 240, p. 616).

“‘It is not necessary, however, that there be independent corroboration of all the contents

of the confession, or even of all the elements of the crime. The requirement of corroboration is

limited to the facts constituting the corpus delicti.’” Aldridge v. Commonwealth, 44 Va. App.

618, 650, 606 S.E.2d 539, 555 (2004) (quoting Watkins v. Commonwealth, 238 Va. 341, 348-49,

385 S.E.2d 50, 54 (1989)). “[C]orroborative evidence supporting the corpus delicti ‘may be

furnished by circumstantial evidence as readily as by direct evidence.’” Id. (quoting Watkins,

238 Va. at 349, 385 S.E.2d at 54) (citation omitted).

“A conviction for knowingly and intentionally possessing a firearm after having been

convicted of a felony, see Code § 18.2-308.2, requires proof beyond a reasonable doubt of either

actual or constructive possession of the firearm.” Hancock v. Commonwealth, 21 Va. App. 466,

468, 465 S.E.2d 138, 140 (1995); see Rawls v. Commonwealth, 272 Va. 334, 349, 634 S.E.2d

697, 705 (2006). To support a conviction based upon constructive possession, the

Commonwealth “‘must point to evidence of acts, statements, or conduct of the accused or other

facts or circumstances which tend to show that the defendant was aware of both the presence and

-3- character of the [item] and that it was subject to his dominion and control.’” Drew v.

Commonwealth, 230 Va. 471, 473, 338 S.E.2d 844, 845 (1986) (quoting Powers v.

Commonwealth, 227 Va. 474, 476, 316 S.E.2d 739, 740 (1984)).

Benguche contends his “confession” was not sufficiently corroborated to support his

conviction. However, he did not confess to a crime. Rather, he merely admitted ownership of

the handgun fired from the vehicle, and offered to “take responsibility for it.” Thus, the question

before us is not whether his “confession” was sufficiently corroborated, but whether his

admission of ownership, combined with the other evidence, was sufficient to prove beyond a

reasonable doubt that he possessed the weapon.

While sufficient evidence of guilt is provided neither by mere proximity to the firearm

nor by mere “occupancy of the premises” where a firearm is found, both proximity and

occupancy are relevant factors that a fact finder may consider in determining guilt. Rawls, 272

Va. at 350, 634 S.E.2d at 705.

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Related

Smallwood v. Com.
688 S.E.2d 154 (Supreme Court of Virginia, 2009)
Rawls v. Com.
634 S.E.2d 697 (Supreme Court of Virginia, 2006)
Morrisette v. WARDEN OF SUSSEX I
613 S.E.2d 551 (Supreme Court of Virginia, 2005)
Roach v. Commonwealth
468 S.E.2d 98 (Supreme Court of Virginia, 1996)
Hunter v. Commonwealth
690 S.E.2d 792 (Court of Appeals of Virginia, 2010)
Wilson v. Commonwealth
681 S.E.2d 74 (Court of Appeals of Virginia, 2009)
Jones v. Commonwealth
660 S.E.2d 343 (Court of Appeals of Virginia, 2008)
Aldridge v. Commonwealth
606 S.E.2d 539 (Court of Appeals of Virginia, 2004)
Archer v. Commonwealth
492 S.E.2d 826 (Court of Appeals of Virginia, 1997)
Hancock v. Commonwealth
465 S.E.2d 138 (Court of Appeals of Virginia, 1995)
Martin v. Commonwealth
358 S.E.2d 415 (Court of Appeals of Virginia, 1987)
Watkins v. Commonwealth
385 S.E.2d 50 (Supreme Court of Virginia, 1989)
Wheeler v. Commonwealth
66 S.E.2d 605 (Supreme Court of Virginia, 1951)
Phillips v. Commonwealth
116 S.E.2d 282 (Supreme Court of Virginia, 1960)
Powers v. Commonwealth
316 S.E.2d 739 (Supreme Court of Virginia, 1984)
Drew v. Commonwealth
338 S.E.2d 844 (Supreme Court of Virginia, 1986)
Wheeler v. Commonwealth
66 S.E.2d 605 (Supreme Court of Virginia, 1951)

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