Phillips v. Commonwealth
In Phillips v. Commonwealth, 202 Va. 207, 210-11, 116 S.E.2d 282, 284 (1960), the Supreme Court overturned a conviction because insufficient evidence other than a confession supported the conviction.
The Court reiterated the well established "'rule in criminal cases . . . that the coincidence of circumstances tending to indicate guilt, however strong and numerous they may be, avails nothing unless the corpus delicti . . . be first established.'" 202 Va. at 211-12, 116 S.E.2d at 285.
The Court ruled that a conviction cannot stand when the corroborating evidence "is just as consistent with non-commission of the offense as it is with its commission." Id. at 212, 116 S.E.2d at 285.