Cases (Circumstantial Evidence) Flashcards
Appellants are charged with the crimes of Murder and of Kidnapping/Serious Illegal Detention in two separate Information. During the trial, AAA, one of the victims, testified: (1) that on May 7, 2002, while she and the victim Abad were sleeping inside the house of the Estrella family, several persons entered to rob the place; (2) Inside the house, she saw and recognized the appellants, and heard one of them uttering “somebody will die; (3) appellants took her outside the house and pushed her into the Revo (vehicle); (4) inside the Revo, she saw inside Abad Sulpacio who was blindfolded and with his hands tied; (5) the last time that she saw Abad Sulpacio was when he was dragged out from the vehicle; (6) during her captivity, AAA was repeatedly rape by the appellants. RTC found the appellants guilty of the crime of Kidnapping/Serious Illegal Detention of AAA and Murder of Abad. Considering that the victim AAA was raped during her detention, the maximum penalty of DEATH was imposed. CA affirmed RTC’s ruling. On appeal with SC, appellants assailed the conviction of murder on the ground that there was no eye-witness presented that they indeed kill Abad.
ISSUE: Whether or not an accused may be convicted even if there are no eye- witness on the commission of the offense.
Yes. The trial court found that although there was no direct eyewitness in the killing of Abad, the prosecution adduced sufficient circumstantial evidence to establish with moral certainty the identities and guilt of the perpetrators of the crime. Circumstantial evidence consists of proof of collateral facts and circumstances from which the existence of the main fact may be inferred according to reason and common experience . Circumstantial evidence is sufficient to sustain conviction if:
(a) there is more than one circumstance;
(b) the facts from which the inferences are derived are proven;
(c) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt.
A judgment of conviction based on circumstantial evidence can be sustained when the circumstances proved form an unbroken chain that results in a fair and reasonable conclusion pointing to the accused, to the exclusion of all others, as the perpetrator.
In the case at bar, although no one directly saw the actual killing of Sulpacio, the prosecution was able to paint a clear picture that the appellants took Sulpacio away from the house of the Estrellas, tied and blindfolded him, and brought him to another place where he was repeatedly shot and buried.
Maritess Alolod, Efren Deocampo, Edwin Deocampo, and Elmer Deocampo were charged with double murder. RTC convicted them considering the following circumstantial evidence: (1) Efren had always been banned from the old couple’s house because they strongly disapproved his relationship with Maritess; (2) The old couple were enjoying good health before of May 27, 1998; (3) On May 28 they suddenly went missing; (4) On the night of May 27 the security guard at Salaman Institute saw Efren and Edwin standing on the school side of the fence next to the old couple’s house. The next day, the guard discovered that the fence wire had been cut; (5) At about 2:00 a.m. of May 28 a `neighbor heard the sound of a woman sobbing and what seemed like the butchering of a pig; (6) At break of dawn, a witness saw Efren in the Alolod kitchen; (7) From then on Efren and his brothers frequented the old couple’s house, with Efren wearing the old man’s watch; (8) Maritess lied about her adoptive parents going to Cotabato City / Davao City for medical treatment when people started looking for them; (9) A witness heard Efren instructing Maritess to plant more camote on a pile of red soil beside the house; and (10) The bodies of the old couple were found underneath those plants. On appeal, Accused Efren Deocampo assailed their conviction based on circumstantial evidence.
ISSUE: Whether or not the CA erred in affirming the RTC’s finding that accused Efren was responsible for the murder of the Alolod couple based on circumstantial evidence.
The rule of evidence that applies when no witness saw the commission of the crime provides:
SEC. 4. Circumstantial evidence, when sufficient. – Circumstantial evidence is sufficient for conviction if:
(a) There is more than one circumstance;
(b) The facts from which the inferences are derived are proven; and (c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.
The circumstances must constitute an unbroken chain that inexorably leads to one fair conclusion: the accused committed the crime to the exclusion of all others.
In this case, the trial court was correct in holding that the accused was guilty due to the following facts: (1) the presence of the accused in the victim’s house and used of the latter’s things when he had always been banned therefrom during the lifetime of the victim; (2) the cover-up story of the adopted daughter that her parent went away for a medical check-up; (3) the planting of camote on the ground where the victim’s where found buried; (4) testimony of a neighbor hearing a scream the night before the victims went missing then seeing the accused inside the house of the victims. All these when taken together leads only to one conclusion, i.e., that the accused is guilty of the crime charged.
The evidence for the prosecution shows that on the evening of April 21, 2007, a certain Adriano Marquez (Marquez) witnessed the robbery perpetrated in the house of Carmencita De Guzman (De Guzman) while she was away to attend to the wake of her deceased husband. No one was left in the house. Marquez, whose house was opposite the house of De Guzman and Celedonio, which were adjacent to each other, identified Celedonio as the culprit. Upon learning of the incident, De Guzman reported it to the police and requested that Celedomo be investigated for possibly having committed the crime, based on the account of Marquez.”Later, a follow-up operation was conducted by PO1 Rommel Roque (PO1 Roque) and SPO2 Adrian Sugui (SPO2 Sugui), accompanied by Marquez. They proceeded to Raja Humabon St., Navotas, to survey the area for the possible identification and apprehension of the suspect. On their way, Marquez pointed to a man on a motorcycle and said, “Sir, siya po si Eduardo Celedonio.” The police immediately flagged down Celedonio. PO1 Roque asked him if he was Eduardo Celedonio, but he did not reply and just bowed his head.”SPO2 Sugui informed Celedonio of a complaint for robbery against him. Celedonio still remained silent and just bowed his head. SPO2 Sugui asked him, “Where are the stolen items?” Celedonio then alighted from his motorcycle and opened its compartment where PO1 Roque saw some of the stolen items, as per report of the incident, such as the portable DVD player and a wristwatch, among others. “PO1 Roque asked Celedonio if the same were stolen, to which the latter answered, “Iyan po.” Thus, Celedonio was arrested and was informed of his constitutional rights. More items were seized from Celedonio at the police station.RTC found Celedonio guilty beyond reasonable doubt of the crime of Robbery with Force Upon Things. Insisting on his innocence, Celedonio appealed to the Court of Appeals (CA), arguing that the RTC erred in convicting him of the crime despite the insufficiency of the circumstantial evidence.
Issue: W/N the honourable Court of Appeals gravely erred in affirming the trial court’s ruling that the petitioner’s guilt was proven based on circumstantial evidence
NO. The SC held that, “Jurisprudence tells us that direct evidence of the crime is not the only matrix from which a trial court may draw its conclusion and finding of guilt. The rules on evidence allow a trial court to rely on circumstantial evidence to support its conclusion of guilt. The lack of direct evidence does not#ipso factobar the finding of guilt against the appellant. As long as the prosecution establishes the accused-appellant’s participation in the crime through credible and sufficient circumstantial evidence that leads to the inescapable conclusion that he committed the imputed crime, the latter should be convicted.”Circumstantial evidence is sufficient for conviction if: 1) there is more than one circumstance; 2) the facts from which the inferences are derived are proven; and 3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.”In this case, the prosecution sufficiently laid down the circumstances that, when taken together, constituted an unbroken chain that led to a reasonable conclusion that Celedonio was the perpetrator. The CA opined that:xxx As correctly pointed out by the trial court, these circumstances are: accused was a next door neighbor of private complainant; he was seen by another neighbor going over the concrete fence separating their houses and ransacking a room in complainant’s house; during the time, no one was inside complainant’s house as all of them were at the wake of private complainant’s recently demised husband; two (2) days after, most of the items discovered to have been stolen that night were found in the compartment of the accused’s motorcycle which he was riding on when accosted by the police; the items recovered from him were identified by the complainant as her stolen property; during the trial accused denied that the stolen items were found in his possession and claimed that they were “planted” by the police investigators to frame him up of the robbery. In short, the accused could not explain his possession of the recently stolen items found in his sole possession.xxxx”We find the conviction of accused-appellant based on circumstantial evidence factually and legally tenable, as the facts from which the aforementioned circumstances arose have been proved through the positive testimony of Adriano Marquez, POi Rommel Roque and Carmencita de Guzman.The defense does not refute the existence of the commission of robbery. In fact, Celedonio himself acknowledged that the prosecution’s circumstantial evidence, although weak, ambiguous and inconclusive, established that 1) a robbery had been committed; 2) it was committed recently; 3) several of the stolen items including cash were found in his possession; and 4) he had no valid explanation for his possession of the stolen goods.”
