The rules of evidence allow a trial court to rely on circumstantial evidence to support its conclusion of guilt.

But even if the confession and evidence gathered as a result of it are disregarded, the evidence that remains still supports the result of the conviction of accused-appellant.

Here, there are no direct witnesses to the crime.  But even if no one saw the commission of the crime, accused-appellant may still be pinned down as the perpetrator.  As held in Salvador v. People:

Direct evidence of the crime is not the only matrix wherefrom a trial court may draw its conclusion and finding of guilt.  The rules of evidence allow a trial court to rely on circumstantial evidence to support its conclusion of guilt.  Circumstantial evidence is that evidence which proves a fact or series of facts from which the facts in issue may be established by inference.  At times, resort to circumstantial evidence is imperative since to insist on direct testimony would, in many cases, result in setting felons free and deny proper protection to the community.[28]

In this particular case, with this particular crime, it is the circumstantial evidence that comes into play to reach a conclusion.  In People v. Pascual, it was held:

It is settled that in the special complex crime of rape with homicide, both the rape and the homicide must be established beyond reasonable doubt.  In this regard, we have held that the crime of rape is difficult to prove because it is generally unwitnessed and very often only the victim is left to testify for herself.  It becomes even more difficult when the complex crime of rape with homicide is committed because the victim could no longer testify.  Thus, in crimes of rape with homicide, as here, resort to circumstantial evidence is usually unavoidable.[29]

Under Sec. 4, Rule 133 of the Rules of Court, circumstantial evidence shall be sufficient for conviction when the following requisites are complied with: (1) there is more than one circumstance; (2) the facts from which the inferences are derived are proved; and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

Salvador also held:

All the circumstances must be consistent with one another, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with the hypothesis that he is innocent.  Thus, conviction based on circumstantial evidence can be upheld, provided that the circumstances proven constitute an unbroken chain which leads to one fair and reasonable conclusion that point to the accused, to the exclusion of all others, as the guilty person.[30]

Setting aside the knife and the bloodied t-shirt recovered from the room of accused-appellant, the CA and the RTC relied on several circumstances to justify the conviction.

http://sc.judiciary.gov.ph/jurisprudence/2011/march2011/188705.htm

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About Erineus

Born on December 28, 1965, Surallah, South Cotabato, Southern Mindanao, Philippines.
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