PEOPLE OF THE PHILIPPINES, PLAINTIFF AND APPELLEE, VS. FABIAN URZAIS Y LANURIAS, ALEX BAUTISTA, AND RICKY BAUTISTA ACCUSED, G.R. No. 207662, April 13, 2016. - The Lawyer's Post.
“x x x.
Certainly, it is not only by direct evidence that an accused may be convicted, but for circumstantial evidence to sustain a conviction, following are the guidelines: (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 as such as to produce a conviction beyond reasonable doubt.4 Decided cases expound that the circumstantial evidence presented and proved 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. All the circumstances 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 every other rationale except that of guilt.5
In the case at bar, notably there is only one circumstantial evidence. And this sole circumstantial evidence of possession of the vehicle does not lead to an inference exclusively consistent with guilt. Fundamentally, prosecution did not offer any iota of evidence detailing the seizure of the vehicle, much less with accused-appellant’s participation. In fact, there is even a variance concerning how accused-appellant was discovered to be in possession of the vehicle. The prosecution’s uncorroborated evidence says accused-appellant was apprehended while driving the vehicle at a checkpoint, although the vehicle did not bear any license plates, while the latter testified he was arrested at home. The following testimony of prosecution witness SPO2 x x x.
Considering the dearth of evidence, the subject vehicle is at best classified as “missing” since the non-return of the victim and his vehicle on 12 November 2002. Why the check-point had begun before then, as early 3 November 2002, as stated by the prosecution witness raises doubts about the prosecution’s version of the case. Perhaps, the check-point had been set up for another vehicle which had gone missing earlier. In any event, accused-appellant’s crime, if at all, was being in possession of a missing vehicle whose owner had been found dead. There is perhaps guilt in the acquisition of the vehicle priced so suspiciously below standard. But how this alone should lead to a conviction for the special complex crime of carnapping with homicide/murder, affirmed by the appellate court is downright disturbing.
X x x.”