ELLA MARIE C.

ABUNDO
2015080082

PEOPLE v. CHAVEZ
G.R. No. 207950. September 22, 2014
LEONEN, J.

FACTS:
The accused was seen by a certain witness claiming that he was seen coming out of the house or parlor of Eric Duque
also known as Barbie at around 2:45 am on October 26, 2008. Then, sometime after 10 am, the police authorities
arrived at the said house and found the dead body of Barbie who suffered 22 stab wounds in different sides of his
body. The said witness was invited by the police for investigation and described the appearance of the person whom
he saw in the crime scene back in October 26. Consequently, the accused, accompanied by his mother, voluntarily
surrendered to the police and the witness positively confirmed that Chavez was the one he saw on October 26. The
accused also affirmed the fact that he went to the victim’s house the night before the dead body was found by the
police. He stated that he went to Barbie’s house to talk about their misunderstandings regarding his relationship
with the victim’s boyfriend, but denied the accusation that he was the one who killed the victim. His mother also
testified about the two cellular phones given to her by his son that were owned by Barbie and that Chavez sold
Barbie’s necklace to a pawnshop, that he threw the knife to the manhole which he used to kill Barbie, that the trails
of evidence of his act could be seen on his slippers and the wound in his hand, and that he only had the intent to rob
Barbie but not to kill him. Thereafter, the accused was charged of the special complex crime of robbery with
homicide. The trial court convicted the accused of the said crime. Hence, he appealed to the appellate court. However,
the Court of Appeals affirmed the lower court’s decision. Hence, this case. Chavez raised the presumption of
innocence, considering that the trial court "overlooked and misapplied some facts of substance that could have
altered its verdict." He argued that since the prosecution relied on purely circumstantial evidence, conviction must
rest on a moral certainty of guilt on the part of Chavez.

ISSUE:
Whether or not Chavez is guilty beyond reasonable doubt of the crime of robbery with homicide.

RULING:
No. The court has held that "what is imperative and essential for a conviction for the crime of robbery with homicide
is for the prosecution to establish the offender’s intent to take personal property before the killing, regardless of the
time when the homicide is actually carried out." In cases when the prosecution failed to conclusively prove that
homicide was committed for the purpose of robbing the victim, no accused can be convicted of robbery with
homicide. The circumstantial evidence relied on by the lower courts do not satisfactorily establish an original
criminal design by Chavez to commit robbery. The object evidence retrieved from the scene of the crime were not
properly handled, and no results coming from the forensic examinations were presented to the court. There was no
examination of the fingerprints found on the kitchen knife retrieved from the manhole near the house of Chavez.
There were no results of the DNA examination done on the hair strands found with the knife and those in the clutches
of the victim. Neither was there a comparison made between these strands of hair and Chavez’s. There was no report
regarding any finding of traces of blood on the kitchen knife recovered, and no matching with the blood of the victim
or Chavez’s. The results of this case would have been rendered with more confidence at the trial court level had all
these been done. In many cases, eyewitness testimony may not be as reliable — or would have been belied — had
object evidence been properly handled and presented. Everyone’s life — whether it be the victim’s or the accused’s
— is valuable. The Constitution and our laws hold these lives in high esteem. Hence, the accused was only convicted
of homicide.