Chain of circumstances

A LAW EACH DAY (KEEPS TROUBLE AWAY) - Jose C. Sison - The Philippine Star

An accused may be found guilty not only by direct evidence but also by circumstantial evidence or that evidence proving a fact or series of facts from which the facts in issue may be established by inference. Resort to such evidence may be necessary because crimes are usually committed without eye-witnesses who can directly testify to their commission and to the identity of the accused. This case of Samuel enumerates the requisites to be complied with for circumstantial evidence to be sufficient for conviction.

Samuel is married to Tina who has just given birth. They are staying in one of the three rooms in the house of Tina’s family. Staying in the two other rooms are the parents of Tina (Mario and Rita) and Tina’s two other sisters, Mayen and Betty.

Even if Samuel is already married to Tina, he seems to be still interested in Tina’s youngest sister Betty. He was caught many times at different places peeping at Betty with lustful eyes. He also continues to maintain his barkada and goes out with them carrying with him a “balisong” or “beinte nueve” which he shows off to his friends.

One evening, when Tina’s parents Mario and Rita and their daughter Mayen went to the province to attend the wake of Mario’s mother, Betty was left in the house with Tina and Samuel. Then Samuel also left to attend a birthday party. At about 9 in the evening, Samuel, accompanied by a friend, Eddie, returned home to get some karaoke tapes they will use in the party. Then he went back to the party and stayed there until 12 midnight before heading back home.

The following day at about 4:30 a.m., the spouses Mario and Rita together with daughter Mayen arrived home. Mario opened the door which was locked. Then Mayen went to the room which she was sharing with Betty. To her shock she saw Betty already dead with stab wounds. Their parents and Tina likewise rushed to the room but Samuel stayed at the sala, crying and then later embraced Tina telling her that he was innocent.

At about 5 a.m. police investigators arrived in response to Mario’s call. They found no forcible entry into the house, no valuables missing, and no blood stains in other parts of the house except in Betty’s room. They also discovered Samuel’s brief, gray T-shirt and short pants on top of the kitchen table; and strands on Betty’s bed. Then they brought these pieces of evidence to the crime laboratory for examination.

The NBI medico legal officer also conducted an autopsy on Betty and found that she suffered 21 stab wounds caused by a pointed instrument, one side of which was sharp like a balisong or kitchen knife. There were also signs that Betty may have struggled with the assailant before she died.

The NBI biologists on the other hand also examined Samuel’s briefs. T-shirt and short pants and found type “O” human blood, Betty’s blood type, on the briefs and shirt. DNA analysis were also conducted on the brief, T-shirt, the strands of hair recovered in Betty’s room, and the Buccal swabs taken from Mario, Rita and Samuel all of which show the presence of human DNA except the brief.

So, on the basis of these evidences, Samuel was charged with the crime of homicide for killing Betty, his sister-in-law. During the presentation of the evidence for the prosecution, the above enumerated facts were established. For his part, Samuel could only offer bare denial of the accusations against him. So the Regional Trial Court rendered a decision finding Samuel guilty of homicide and sentenced him to imprisonment of 8 years, 8 months and 1 day, minimum up to 14 years, 8 months and 1 day, maximum plus payment of corresponding indemnity and moral damages. This decision was affirmed by CA on appeal by Samuel.

Samuel however still went to the Supreme Court. He questioned the sufficiency of each and every circumstance to prove his guilt beyond doubt.

But the Supreme Court still affirmed the decision of the RTC and the CA. The SC said that under Section 4, Rule 133 of the Rules of Court, circumstantial evidence is sufficient if the following requisites are complied with: (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 reasonable doubt.

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. 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 pointing to the accused, to the exclusion of all the others, as the guilty person.

In this case, both the RTC and the CA considered these pieces of evidence in finding Samuel’s guilt: (1) the non-employment of force in entering the scene of the crime; (2) no missing personal belongings; (3) absence of bloodstains in other parts of the house except Betty’s room; (4) Samuel’s ownership of a balisong, the same weapon used in stabbing the victim; (5) the presence of type “O” human blood on Samuel’s T-shirt and briefs; (6) the positive result of the DNA analysis using bloodstains found in Samuel’s shirt and briefs; and (7) Samuel’s unusual behavior after the discovery of Betty’s lifeless body.

These individual pieces of evidence may not be sufficient to point to Samuel as the author of the crime. However, when taken together, they are more than enough to establish beyond reasonable doubt that Samuel committed the crime of homicide. The peculiarity of circumstantial evidence is more like a puzzle which, when put together, reveals a remarkable picture pointing toward the conclusion that the accused is the author of the crime.

So Samuel is really guilty of homicide and should suffer imprisonment of 8 years and 1 day minimum, to 14 years, 8 months and 1 day, maximum plus the corresponding indemnity, moral and temperate damages (Salvador vs. People, G.R. 164266, July 22, 2008).

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