It is a settled rule that circumstantial evidence is sufficient to support a conviction, and that direct evidence is not always necessary.

This is but a recognition of the reality that in certain instances, due to the inherent attempt to conceal a crime, it is not always possible to obtain direct evidence.

In Bacolod v. People, this Court had the occasion to say:

The lack or absence of direct evidence does not necessarily mean that the guilt of the accused cannot be proved by evidence other than direct evidence. Direct evidence is not the sole means of establishing guilt beyond reasonable doubt, because circumstantial evidence, if sufficient, can supplant the absence of direct evidence. The crime charged may also be proved by circumstantial evidence, sometimes referred to as indirect or presumptive evidence. Circumstantial evidence has been defined as that which “goes to prove a fact or series of facts other than the facts in issue, which, if proved, may tend by inference to establish a fact in issue.”

The Rules of Court itself recognizes that circumstantial evidence is sufficient for conviction, under certain circumstances:

Sec. 4. Circumstantial evidence, when sufficient. – 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;

(3) The combination of all the circumstances is such as to produce a conviction beyond a reasonable doubt.

Moreover, in Lozano v. People, this Court clarified the application of the circumstantial evidence rule:

To sustain a conviction based on circumstantial evidence, it is essential that the circumstantial evidence presented must constitute an unbroken chain which leads one to a fair and reasonable conclusion pointing to the accused, to the exclusion of the others, as the guilty person. The circumstantial evidence must exclude the possibility that some other person has committed the crime.

The settled rule is that a judgment of conviction based purely on circumstantial evidence can be upheld only if the following requisites concur: (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 conviction beyond reasonable doubt. The corollary rule is that the circumstances proven must constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused, to the exclusion of all others, as the guilty person, i.e., the circumstances proven must be consistent with each other, consistent with the hypothesis that the accused is guilty and at the same time inconsistent with the hypothesis that he is innocent and with any other rational hypothesis except that of guilt.

Preliminarily, we note that the lack of direct evidence does not ipso facto bar the finding of guilt against the appellant. As long as the prosecution establishes the appellant’s participation in the crime through credible and sufficient circumstantial evidence that leads to the inescapable conclusion that the appellant committed the imputed crime, the latter should be convicted.

According to Section 4, Rule 133 of the Rules of Court, 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.”

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In People v. Solangon, we convicted accused Ricardo Solangon on the strength of circumstantial evidence. In Solangon, even though no direct evidence was presented to prove that the accused (alleged to have been members of the NPA) actually killed the victim, we still upheld the conviction.

In People v. Oliva, we upheld the conviction of the accused based on circumstantial evidence. In Oliva, the victim was abducted from his home, was last seen alive in the custody of the accused, and was hog-tied with coralon rope. Although no one saw the actual killing, we held that there was sufficient circumstantial evidence to find the accused guilty beyond reasonable doubt.

In yet another case – People v. Corfin – we upheld the conviction of the accused based on evidence showing that: (1) the accused was the last person seen with the victim; (2) the accused and the victim were seen together near a dry creek; (3) the accused was seen leaving the place alone; and (4) the body of the victim was later found in the dry creek.

All these cases show that the Court, when presented with sufficient circumstantial evidence, will not shirk from upholding an accused’s conviction for murder. There are more than enough reasons to similarly act in this case where the law and the attendant facts, considered in relation to one another, lead to the single conclusion that the appellant participated in the killing of Resuelo, Sr.

Circumstantial evidence consists of proof of collateral facts and circumstances from which the main fact in issue may be inferred based on reason and common experience. Under Section 4, Rule 133 of the Revised Rules of Court, circumstantial evidence is sufficient for conviction if the following requisites concur: (a) there is more than one circumstance; (b) the facts from which the inferences are derived have been established; and (c) the combination of all the circumstances unavoidably leads to a finding of guilt beyond reasonable doubt. These circumstances must be consistent with one another, and the only rational hypothesis that can be drawn therefrom must be the guilt of the accused.

For circumstantial evidence to be sufficient for conviction, the following conditions must be satisfied:

(a) There is more than one circumstance;

(b) The facts from which the circumstances are derived are proven; and

(c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

Circumstantial evidence suffices to convict an accused only if the circumstances proved constitute an unbroken chain which leads to one fair and reasonable conclusion that points to the accused, to the exclusion of all others as the guilty person; the circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with any other hypothesis except that of guilty.

 

Atty. Francesco C. Britanico