Thursday, April 29, 2021
Circumstantial evidence - "Conviction can be had on the basis of circumstantial evidence if the established circumstances constitute an unbroken chain leading to a fair and reasonable conclusion proving that the appellant is the author of the crime to the exclusion of all others."
See - https://lawphil.net/judjuris/juri2002/dec2002/gr_147649_2002.html
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANK LOBRIGAS, MARLITO LOBRIGAS (At Large) and TEODORICO MANTE (acquitted), accused. FRANK LOBRIGAS, accused-appellant. G.R. No. 147649, December 17, 2002.
“X x x.
In order to warrant a conviction, direct evidence is not always required. Conviction can be had on the basis of circumstantial evidence if the established circumstances constitute an unbroken chain leading to a fair and reasonable conclusion proving that the appellant is the author of the crime to the exclusion of all others.4 The rules on evidence and jurisprudence sustain the conviction of an accused through circumstantial evidence when the following requisites concur: (1) there is more than one circumstance; (2) the inference must be based on proven facts; and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.5
The circumstances proved by the prosecution and relied upon by the trial court to convict accused-appellant clearly satisfied the foregoing requirements. First, the victim, accused appellant and others were together having a drinking spree on the day the mauling happened. Second, the victim declared to Castor Guden immediately after the incident that accused-appellant and two others mauled him can be considered as part of the res gestae. Third, the victim told his daughter immediately after the incident, that accused-appellant was one of the persons who mauled him. Fourth, Dr. Tito L. Miranda found that the victim died due to massive hemorrhage in his thoracic cavity caused by severe beating of his breast. Lastly, accused-appellant evaded arrest and subsequently escaped from detention. The foregoing circumstances knitted together proved accused-appellant’s culpability beyond reasonable doubt.
X x x.”