Circumstantially guilty

Most crimes are carried out clandestinely and without any eyewitnesses, especially the crime of murder. Even the victims can no longer testify on what happened to them precisely because they are already dead. So the crime can only be proven by a chain of circumstances pointing to the culprits who perpetuated the crime. When may these circumstances be considered sufficient to support a finding of guilty beyond reasonable doubt? This is answered in this case for today.

This case is about an elderly couple, Lolo Bong and Lola Raquel residing in a remote barrio down south with their adopted daughter Jecel who has two children with her lover, Leonard. Lolo Bong and Lola Raquel never allowed Leonard to set foot on their house since they loathed him.

One day, the old couple who were still in good health disappeared. Their neighbor Aling Carmen even saw Lolo Bong went to market early in the day. On the evening of that day, David, a security guard of a nearby school, saw Leonard and Tony standing near the fence separating the school from the couple’s house as he was making the rounds.

On the early morning of the following day about 2 a.m., Aling Carmen’s husband Rod was awakened by strange sounds coming from a woman sobbing and from a pig being butchered. He looked out through the window, but seeing no one, he went back to bed. Then at 5:30 a.m. he saw Leonard at the kitchen of the old couples’ house.

Despite Jecel’s attempt to hide from their neighbors and even from the couple’s family as to what really happened to them, it was discovered that Lolo Bong and Lola Raquel did not really go to the city as narrated by Jecel, and their clothes were still in their cabinet. After searching the house for clues, Meann’s father noticed a portion of land planted with camote. And when they dug up the place, they found the decomposing bodies of the couple.

So after the preliminary investigation, the private prosecutor charged Leonard, Jecel, Tony and Gio with double murder in the Regional Trial Court (RTC) where Meann, and her parents, Rod and April together with Rita and the security guard testified on the circumstances they witnessed, pointing to the four accused as the persons liable for the killing of Lolo Bong and Lola Raquel.

After more than three years of hearing the case, the RTC found the four accused guilty of murdering Lola Raquel with Leonard and Tony as principals and Jecel and Gio as accessories. The four accused were also found guilty of murdering Lolo Bong. In each case, the RTC sentenced Leonard and Tony to suffer the death penalty while Jecel and Gio was sentenced to suffer imprisonment of four years two months minimum to 10 years as maximum plus damages and costs.

While pending appeal to the CA, Jecel, Tony and Gio decided to withdraw their appeal leaving Leonard as the sole accused appellant. Was Leonard guilty of murder of the old couple based on circumstantial evidence?

The Court of Appeals said yes, but sentenced Leonard to reclusion perpetua only. This was affirmed by the Supreme Court (SC) except as to damages which was increased to P205,000. The SC said that 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 prove a conviction beyond reasonable doubt. The circumstances must constitute an unbroken chain that inexorably leads to one fair conclusion that accused committed the crime to the exclusion of the others. Here the circumstances abound: (1) Leonard had always been banned from the couple’s house because they strongly disapproved his relationship with Jecel; (2) they were in good health before they disappeared one evening; (3) they were suddenly gone from the house one evening which means they were killed that night or the following morning; (4) on the night of their disappearance the security guard of the nearby school saw Leonard and Tony standing on the school side of the fence next to the old couples’ house. They even tried to conceal themselves in the school toilet. The next day, the guard noticed that the fence wire had been cut; (5) at about 2 am the following morning 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 Leonard at the kitchen of the victims; (7) from then on, Leonard and his brothers frequented the old couples’ house with Leonard wearing the old man’s wristwatch; (8) Jecel definitely lied about her adoptive parents going to two different cities for medical treatment; (9) a witness heard Leonard aiming 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 (People vs Efren Deocampo, G.R. 185212, February 15, 2012)

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