California Penal Code Section 1111 - Interpretation
Section 1111 provides, in pertinent part, that 'a conviction cannot be had upon the testimony of an accomplice unless it be corroborated by such other evidence as shall tend to connect the defendant with the commission of the offense.'
In People v. Perry (1972) 7 Cal.3d 756 at page 769 , the Court reviewed the standard by which the sufficiency of corroborating evidence is to be measured: 'To corroborate the testimony of an accomplice, the prosecution must produce independent evidence which, without aid or assistance from the testimony of the accomplice, tends to connect the defendant with the crime charged.
"The evidence need not corroborate the accomplice as to every fact to which he testifies but is sufficient if it does not require interpretation and direction from the testimony of the accomplice yet tends to connect the defendant with the commission of the offense is such a way as reasonably may satisfy a jury that the accomplice is telling the truth; it must tend to implicate the defendant and therefore must relate to some act or fact which is an element of the crime but it is not necessary that the corroborative evidence be sufficient in itself to establish every element of the offense charged. . . .
The corroborative evidence may be slight and entitled to little consideration when standing alone.' (Accord, People v. Szeto (1981) 29 Cal.3d 20, 27.)" (People v. Bunyard (1988) 45 Cal.3d 1189, 1206 (Bunyard); accord, People v. Davis (2005) 36 Cal.4th 510, 541.)
Corroborating evidence may be entirely circumstantial (People v. Hayes (1999) 21 Cal.4th 1211, 1271; People v. Rodrigues (1994) 8 Cal.4th 1060, 1128 (Rodrigues)) and "'"slight and entitled to little consideration when standing alone'" (People v. Sanders (1995) 11 Cal.4th 475, 534-535, quoting People v. Miranda (1987) 44 Cal.3d 57, 100).
"'Corroborating evidence is sufficient if it substantiates enough of the accomplice's testimony to establish his credibility.'" (Bunyard, supra, 45 Cal.3d at pp. 1206-1207; accord, Rodrigues, supra, 8 Cal.4th at p. 1128.)