PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, V. GIRALYN P. ADALIA ACCUSED-APPELLANT. G.R. No. 235990, January 22, 2020 .
“x x x.
In the main, appellant asserts that there was no direct evidence to prove that the charge of infanticide against her, hence, she should have been acquitted.
The absence alone of direct evidence against an accused does not per se compel a finding of innocence. Circumstantial evidence may be offered to take the place of direct evidence, especially in cases involving crimes which by their nature are usually committed in utmost secrecy. People v. Pentecostes47 decreed that circumstantial evidence is by no means a "weaker" form of evidence vis-a-vis direct evidence. It elaborated:
Direct evidence of the commission of a crime is not indispensable to criminal prosecutions; a contrary rule would render convictions virtually impossible given that most crimes, by their very nature, are purposely committed in seclusion and away from eyewitnesses. Thus, our rules on evidence and jurisprudence allow the conviction of an accused through circumstantial evidence alone, provided that the following requisites concur:
(i) there is more than one circumstance;
(ii) the facts from which the inferences are derived are proven; and
(iii) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.
Simply put, an accused may be convicted when the circumstances established form an unbroken chain leading to one fair reasonable conclusion and pointing to the accused - to the exclusion of all others - as the guilty person.
xxx xxx xxx
In People v. Casitas, Jr.,48 the Court explained that establishing guilt through circumstantial evidence is akin to weaving a "tapestry of events that culminate in a vivid depiction of the crime of which the accused is the author."
Here, the following circumstances make up the chain of events which culminated in a graphic portrayal of how appellant's cold-blooded slaying of her newborn child was committed, viz.: x x x.
X x x.”
In the main, appellant asserts that there was no direct evidence to prove that the charge of infanticide against her, hence, she should have been acquitted.
The absence alone of direct evidence against an accused does not per se compel a finding of innocence. Circumstantial evidence may be offered to take the place of direct evidence, especially in cases involving crimes which by their nature are usually committed in utmost secrecy. People v. Pentecostes47 decreed that circumstantial evidence is by no means a "weaker" form of evidence vis-a-vis direct evidence. It elaborated:
Direct evidence of the commission of a crime is not indispensable to criminal prosecutions; a contrary rule would render convictions virtually impossible given that most crimes, by their very nature, are purposely committed in seclusion and away from eyewitnesses. Thus, our rules on evidence and jurisprudence allow the conviction of an accused through circumstantial evidence alone, provided that the following requisites concur:
(i) there is more than one circumstance;
(ii) the facts from which the inferences are derived are proven; and
(iii) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.
Simply put, an accused may be convicted when the circumstances established form an unbroken chain leading to one fair reasonable conclusion and pointing to the accused - to the exclusion of all others - as the guilty person.
xxx xxx xxx
In People v. Casitas, Jr.,48 the Court explained that establishing guilt through circumstantial evidence is akin to weaving a "tapestry of events that culminate in a vivid depiction of the crime of which the accused is the author."
Here, the following circumstances make up the chain of events which culminated in a graphic portrayal of how appellant's cold-blooded slaying of her newborn child was committed, viz.: x x x.
X x x.”
