Facts:

Issue:

Decision:

Hierarchy of Evidence

Overwhelming Evidence

Proof Beyond Reasonable Doubt

People vs Caliso

Facts:

Issue:

Decision:

People of the Philippines vs Felimon Patentes

G.R. No. 190178
12 February 2014

Facts:
On 05 December 1998, AAA boarded a bus going to her grandmother’s house. While seated, Felimon Patentes,
whom she knew as a friend of her brother boarded and sat beside her. After a brief conversation, Patentes showed
her his bolo and red steel pipe. He threatened her to kill AAA with it if she will not obey him. Patentes brought her
to his house where his immediate family, nephews and neices live as well. There he had carnal knowledge with
AAA after forcing her to inhale from the red steel pipe causing her to become nauseous. After eight days of being
raped, AAA convinced Patentes that she will marry him if he sets her free. Patentes mother then accompanied AAA
back to her home. When AAA got the chance to be alone with her mother she was then able to tell her what
Patentes did to her. Whereas, Patentes claim that AAA went with him freely and the sexual intercourse was with
her consent. Patentes presented his neighbor who saw AAA roam around the area doing chores and conversed
with him regarding Patentes and AAAs wedding plan. AAAs friends who visited Patentes house corroborated the
same. The Regional Trial Court convicted Patentes. The appellate court affirmed the lower court’s decision.

Issue:
Whether or not the court has proven beyond reasonable doubt the crime committed by Patentes?

Decision:
The Supreme Court reversed the appellate court’s decision. The numerous inconsistencies in AAA’s testimony have
created reasonable doubt.
A conviction in a criminal case must be supported by proof beyond reasonable doubt, which means a moral
certainty that the accused is guilty; the burden of proof rests upon the prosecution. In the case at bar, the
prosecution has failed to discharge its burden of establishing with moral certainty the truthfulness of the charge
that appellant had carnal knowledge of AAA against her will using threats, force or intimidation.

Clear and Convincing

Supreme Court vs Delgado

Facts:

Issue:

Decision:

Government of Hong Kong Special Administrative Region, represented by the Philippine Department of Justice
vs Hon. Felixberto Olalia
G.R. No. 153675
19 April 2007

Facts:
On 30 January 1995, the Republic of the Philippines signed an agreement with the then British Crown Colony of
Hong Kong signed an "Agreement for the Surrender of Accused and Convicted Persons." This took effect on 20
June 1997. On 13 September 1999, the Department of Justice (DOJ) received from Hong Kong Department of
Justice a request for the provisional arrest of Juan Antonio Muñoz who was charged before the Hong Kong Court
with three counts of the offense of "accepting an advantage as agent," and seven counts of the offense of
conspiracy to defraud, penalized by the common law of Hong Kong. The request was forwarded to the National
Bureau of Investigation (NBI) and then the Regional Trial Court. Order of arrest was then issued and NBI arrested
Muñoz. Muñoz filed with the Court of Appeals a petition for certiorari, prohibition and mandamus with application
for preliminary mandatory injunction and/or writ of habeas corpus questioning the validity of the Order of Arrest.
The appellete court declared the order void.

Simultaneously in 1999, the Hong Kong Special Administrative Region filed with the RTC of Manila a petition for the
extradition of Muñoz. Muñoz filed petition for bail which was denied citing that there is no Philippine law granting
bail in extradition cases and that private respondent is a high "flight risk." Motion for reconsideration by Muñoz
was granted on 2001. Hence petitioner filed an urgent motion to vacate the order but was denied.

Issue:
Whether or not Muñoz is entitled to bail based on clear and convincing evidence?

Decision:
The Supreme Court dismissed the petition and remanded the case for the trial court to determine whether private
respondent is entitled to bail on the basis of "clear and convincing evidence."

An extradition proceeding being sui generis, the standard of proof required in granting or denying bail can neither
be the proof beyond reasonable doubt in criminal cases nor the standard of proof of preponderance of evidence in
civil cases. While administrative in character, the standard of substantial evidence used in administrative cases
cannot likewise apply given the object of extradition law which is to prevent the prospective extraditee from
fleeing jurisdiction.
In his Separate Opinion in Purganan, then Associate Justice, now Chief Justice Reynato S. Puno, proposed that a
new standard which he termed "clear and convincing evidence" should be used in granting bail in extradition
cases. According to him, this standard should be lower than proof beyond reasonable doubt but higher than
preponderance of evidence. The potential extraditee must prove by "clear and convincing evidence" that he is not
a flight risk and will abide with all the orders and processes of the extradition court.

People vs Fontanilla

Facts:

Issue:

Decision:

Preponderance of Evidence
Philippine Commercial Internatiional Bank vs Antonio Balmaceda and Rolando Ramos
G.R. No. 158143
21 September 2011

Facts:
Antonio Balmaceda was the branch manager of Philippine Commercial International Bank (PCIB) Sta. Cruz, Manila
branch. From 1991 to 1993, Balmaceda allegedly used his position in the bank to fraudulently obtaina nd encash
managers checks in the total amount of PhP 10,782,150. This promtted the bank to file an action for recovery of
sum of money with damages before the Regional Trial Court. Sometime later, the bank amended the complaint
and impleaded Rolando Ramos, Balmaceda’s brother-in-law and recipient of a portion of the encashed amount.
Ramos denied the allegation contending that the amount he received from Balmaceda was payment for the
fighting cocks he sold to the latter. The court decided in favour of the bank. On appeal, the Court of Appeals held
that no sufficient evidence existed to prove tha Ramos colluded with Balmaceda in commiting the fraud.

Issue:
Whether or not the Court of Appeals erred in holding that there is no evidence to hold Ramos conspired with
Balmaceda?

Decision:
The Supreme Court affirmed the appellate court’s decision. PCIB had to prove by preponderance of evidence its
positive assertion that Ramos conspired with Balmaceda in perpetrating the latters scheme to defraud the Bank.

The party who asserts the affirmative of an issue has the onus to prove his assertion in order to obtain a favorable
judgment, subject to the overriding rule that the burden to prove his cause of action never leaves the plaintiff. For
the defendant, an affirmative defense is one that is not merely a denial of an essential ingredient in the plaintiff's
cause of action, but one which will constitute an "avoidance" of the claim if established.

T he mere fact that Balmaceda made Ramos the payee on some of the Managers checks is not enough basis to
conclude that Ramos was complicit in Balmacedas fraud; a number of other people were made payees on the
other Managers checks yet PCIB never alleged them to be liable, nor did the Bank adduce any other evidence
pointing to Ramos participation that would justify his separate treatment from the others. Ramos being alamceda’s
brother-in-law, their relationship is not suffiicent by itself to render Ramos liable without concrete proof of his
participation.
Dra. Leila Dela Llano vs Rebecca Biong, doing business under the name and style of Pongkay Trading
G.R. No. 182356
04 December 2013

Facts:
On the evening of 30 March 2000, Dra. Leila Dela Llana was seated at the front passenger seat of his brother’s car
when a dump truck rammed the car’s rear end when they stopped on red signal. She suffered minor wounds
without any other visible injuries. Traffic investigation report identified the driver, Joel Primero, driving the truck
with reckless imprudence. Joel was delivering gravel and sand for his employer, Rebecca Biong, doing business
under the name and style of "Pongkay Trading." Five weeks after, Dra. Dela Llana felt moderate pain on her neck
which became severe as days passed by. She underwent various consultations, theraphy and an operation until
October that year. The findings was due to whiplash injury. The operation released the impingement of the nerve,
but incapacitated Dra. Dela Llana from the practice of her profession since June 2000 despite the surgery. Dra. Dela
Llana demanded from Biong compensation for her injuries, which the latter refused to pay. The former sued Biong
for damages.

The Regional Trial Court ruled in favour of Dra. Dela Llana and held that the proximate cause of Dra. dela Llana’s
whiplash injury to be Joel’s reckless driving. Biong assailed the decision. The Court of Appeals reversed citing that
Dra. dela Llana failed to establish a reasonable connection between the vehicular accident and her whiplash injury
by preponderance of evidence. It noted that the interval between the date of the collision and the date when Dra.
dela Llana began to suffer the symptoms of her illness was lengthy. It concluded that this interval raised doubts on
whether Joel’s reckless driving and the resulting collision in fact caused Dra. dela Llana’s injury. It also declared that
courts cannot take judicial notice that vehicular accidents cause whiplash injuries. It observed that Dra. dela Llana
did not immediately visit a hospital to check if she sustained internal injuries after the accident. Moreover, her
failure to present expert witnesses was fatal to her claim. It also gave no weight to the medical certificate. The
medical certificate did not explain how and why the vehicular accident caused the injury.

Issue:
Whether or not Dra. Dela Llana was able to establish her claim by preponderance of evidence?

Decision:
The Supreme Court affirmed the decision. Dra. Dela Llana failed to establish her case by preponderance of
evidence.

The burden of proving the proximate causation between Joel’s negligence and Dra. Dela Llana’s whiplash injury
rests on Dra. Dela Llana. She must establish by preponderance of evidence that Joel’s negligence, in its natural and
continuous sequence, unbroken by any efficient intervening cause, produced her whiplash injury, and without
which her whiplash injury would not have occurred.

Based on the elements necessary to establish a quasi-delict case, Dra. Dela Llana should show the chain of
causation between Joel’s reckless driving and her whiplash injury. Only after she has laid this foundation can the
presumption - that Rebecca did not exercise the diligence of a good father of a family in the selection and
supervision of Joel - arise. She anchored her claim on merely three pieces of evidence (pictures of damaged car,
medical certificate and her testimony) which did not establish negligence, the damages and the proximate
causation.

Canlao vs People

Facts:

Issue:
Decision:

Substantial Evidence
Office of the Ombudsman vs Reyes

Facts:

Issue:
Whether or not the charge of grave misconduct against Reyes was sufficiently proven by substantial evidence?

Decision:
The Supreme Court reversed the appellate court’s decision.

Section 27 of Republic Act No. 6770 mandates that the findings of fact by the Office of the Ombudsman are
conclusive when supported by substantial evidence. In administrative and quasi-judicial proceedings, only
substantial evidence is necessary to establish the case for or against a party. Substantial evidence is more than a
mere scintilla of evidence. It is that amount of relevant evidence that a reasonable mind might accept as adequate
to support a conclusion, even if other minds, equally reasonable, might conceivably opine otherwise.

Xavier Ramos vs BPI Family Savings Bank Inc. and/or Alfonso Salcedo Jr.
G.R. No. 203186
04 December 2013

Facts:
Xavier Ramos was employed by BPI Family Savings Bank (BPI) in 1995 and eventually became its Vice-President for
Dealer Network Marketing / Auto Loans Division. During his tenure, Trezita Acosta obtained serveral auto and real
estate loans from the bank which were duly approved and promptly paid. On 15 December 2004, Acosta allegedly
secured another auto loan and became delinquent. It turned out that Acosta did not authorize the said loan. Upon
the bank’s investigation, it found that someone misrepresented Acosta and the car was released from Toyota
based on the Purchase Order and Authority to Deliver issued by Ramos which were released without approval of
the credit committee. The loss acquired by the bank was divided amongst Ramos, his three subordinates and the
bank proportionately. Ramos portion was deducted from his benefits and retirement pay. He also executed a
Release, Waiver and Quitclaim on 21 June 2006.

Ramos filed a complaint for underpayment of retirement benefits and non- payment of overtime and holiday pay
and premium pay against BPI Family and/or its President at that time, Alfonso L. Salcedo, Jr., before the National
Labour Relations Commission (NLRC). The Labour Arbiter dissmissed the case and ruled that the deductions were
legal and even reasonable. On appeal, NLRC reversed citing that the deduction was illegal and unreasonable as the
alleged negligence of Ramos was not substantially proven. BPI appealed to the Court of Appeals. The appellate
court affirmed the Labour Arbiter’s decision.

Issue:
Whether or not the Court of Appeals erred in attributing grave abuse of discretion on the part of the NLRC when it
found the deduction made from Ramos’s retirement benefits to be illegal and unreasonable.

Decision:
The Supreme Court reversed the Court of Appeals ruling. To justify the grant of the extraordinary remedy of
certiorari, the petitioner must satisfactorily show that the court or quasi-judicial authority gravely abused the
discretion conferred upon them. Grave abuse of discretion connotes judgment exercised in a capricious and
whimsical manner that is tantamount to lack of jurisdiction.

In labor disputes, the NLRC’s findings are said to be tainted with grave abuse of discretion when its conclusions are
not supported by substantial evidence.

The Court of Appeals only examines the factual findings of the NLRC to determine whether or not the conclusions
are supported by substantial evidence whose absence points to grave abuse of discretion amounting to lack or
excess of jurisdiction. The appellate court does not assess and weigh the sufficiency of evidence upon which the
Labor Arbiter and the NLRC based their conclusion. It is only limited to the determination of whether or not the
NLRC acted without or in excess of its jurisdiction or with grave abuse of discretion in rendering its decision. As an
exception, the appellate court may examine and measure the factual findings of the NLRC if the same are not
supported by substantial evidence.

NLRC correctly observed that BPI Family was not able to substantially prove its imputation of negligence against
Ramos. Well-settled is the rule that the burden of proof rests upon the party who asserts the affirmative of an
issue. BPI Family failed to establish that the duty to confirm and validate information in credit applications and
determine credit worthiness of prospective loan applicants rests with the Dealer Network Marketing Department,
which is the department under the supervision of Ramos. Also, Ramos merely followed standing company practice
when he issued the PO and ATD without prior approval from the bank’s

Credit Services Department. In fact, as the CA itself notes, BPI Family adopted the practice of processing loans with
extraordinary haste in order to overcome arduous competition with other banks and lending institutions, despite
compromising procedural safeguards.

Prima Facie Evidence

Jesse Lucas vs Jesus Lucas
G.R. No. 190710
06 June 2011

Facts:
Elsie Uy migrated from Davao to Manila and stayed with a certain Ate Belen who worked at a nightspot in Manila.
Uy would oftentimes accompany Belen to her work. During this time, Uy got acquainted with Jesus Lucas at Belen’s
workplace. They had an intimate relationship and Uy got pregnant later. Uy gave birth to Jesse Lucas on 11 March
1969. His father’s name was not indicated in his birth certificate but was told by his mother of who his father is.
Jesus allegedly extended financial support to Jesus for about two years. Uy also made attempts to introduce Jesse
to Jesus.

On 26 July 2007, Jesse ifled a Petition to Establish Illegitimate Filiation (with Motion for the Submission of Parties
to DNA Testing. The Regional Trial Court initially dismissed the case citing Herrera vs Alba, “there are four
significant procedural aspects of a traditional paternity action which the parties have to face: a prima facie case,
affirmative defenses, presumption of legitimacy, and physical resemblance between the putative father and the
child. The court opined that petitioner must first establish these four procedural aspects before he can present
evidence of paternity and filiation, which may include incriminating acts or scientific evidence like blood group test
and DNA test results.” Jesse filed a motion for reconsiderationa an hearing for the petition with petition to submit
parties to DNA test was set. Jesus challened this and contends that there is no prima facie case hence the petition
should be dismissed. Regional Trial Court denied Jesus motion. The Court of Appeals reversed the said decision
citing that the four significant procedural aspects of a traditional paternity action had not been met. The Court of
Appeals further held that a DNA testing should not be allowed when the petitioner has failed to establish a prima
facie case.

Issue:
Whether or not showing of prima facie evidence necessary before a court can issue a DNA testing order?

Decision:
The Supreme Court reversed the Court of Appeals decision. During the hearing on the motion for DNA testing, the
petitioner must present prima facie evidence or establish a reasonable possibility of paternity. Notwithstanding
these, the issuance of a DNA testing order remains discretionary upon the court. If there is already preponderance
of evidence to establish paternity and the DNA test result would only be corroborative, the court may, in its
discretion, disallow a DNA testing.

Section 4 of the Rule on DNA Evidence merely provides for conditions that are aimed to safeguard the accuracy
and integrity of the DNA testing. This does not mean that a DNA testing order will be issued as a matter of right if
during the hearing the said conditions are established.

The Supreme Court of Louisiana explained: “Although a paternity action is civil, not criminal, the constitutional
prohibition against unreasonable searches and seizures is still applicable, and a proper showing of sufficient
justification under the particular factual circumstances of the case must be made before a court may order a
compulsory blood test. Courts in various jurisdictions have differed regarding the kind of procedures which are
required, but those jurisdictions have almost universally found that a preliminary showing must be made before a
court can constitutionally order compulsory blood testing in paternity cases. We agree, and find that, as a
preliminary matter, before the court may issue an order for compulsory blood testing, the moving party must show
that there is a reasonable possibility of paternity. As explained hereafter, in cases in which paternity is contested
and a party to the action refuses to voluntarily undergo a blood test, a show cause hearing must be held in which
the court can determine whether there is sufficient evidence to establish a prima facie case which warrants
issuance of a court order for blood testing.”

Probable Cause
Philippine National Bank vs Amelio Tria and John Doe
G.R. No. 193250
25 April 2012

Facts:
Amelio C. Tria (Tria) was a former Branch Manager of petitioner Philippine National Bank (PNB), assigned at PNBs
Metropolitan Waterworks and Sewerage System Branch (PNB-MWSS) located within the Metropolitan Waterworks
and Sewerage System (MWSS) Compound, Katipunan Road, Balara, Quezon City.

MWSS opened current account No. 244-850099-6 at PNB-MWSS with initial deposit PhP 6,714,621.13. This
became dormant by 16 April 2003.

Tria, one time requested for a list of dormant accounts and inquired about the irregularities involving managers
checks. On 22 April 2004, PNB-MWSS received a letter-request from MWSS instructing to issue PhP 5,200,000
worth of managers check payable to Atty. Rodrigo Reyes. This letter-request was evaluated and verified.

On 26 April 2004, despite sufficient available cash in PNB-MWSS, Tria accompamied Atty Reyes to PNB Quezon City
Circle Branch (PNB-Circle) for the encashment of the managers check. Tria proded the Sales and Service Office
(SSO) of PNB-Circle, George Flandez to receive the cash the same day and that Tria will just sign the check to prove
that he identified Atty. Reyes.
In the same month, Tria revised the minutes of the meeting from 06 August 2004 after it has been signed by all the
attendees. He inserted the portion where he identified himself as branch manager who “assists in accompanying
valued client/clients to QC Circle Branch for encashment of MCs merely to identify the bearer/payee and
confirmation of the MC whenever we are short in cash.” Tria then retired by November 2004.

On 14 February 2005 MWSS wrote to the new branch manger of PNB-MWSS, Ofelia Daway, expressing surprise at
the withdrawal and demanding the refund or restoration of the same amount. PNB conducted its own
investigation and soight to hold Tria liable for qualified theft.

Tria contends that (1) there was no taking of personal property; (2) there was no intent to gain on his part; (3) the
personal property does not belong to PNB even if it is the depositary bank; (4) there was no grave abuse of
confidence on his part; and (5) his alleged identification of the payee is not the operative act that triggered the
payment of the managers check by the PNB-MWSS Branch. Instead, Tria argued that it was Flandez who approved
and paid the managers check even beyond his authority. He added that it was the other bank employees who
should be held liable for the loss.

The Assistant City Prosecutor did not find probable cause to file information against Tria citing that Tria’s
identification of the payee did not consummate the payment of the Managers Check. Rather, it was held, the
consummation of the payment occurred during Flandez approval of the encashment. PNB elevated the matter to
Department of Justice and Court of Appeals. Both affirmed that no probable cause was established against Tria.

Issue:
Whether or not the DOJ erred in failing to consider the existence of probable cause?

Decision:
The Supreme Court reversed the decision of the Court of Appeals. There was more than probable cause to proceed
against Tria for qualified theft.

Probable cause, for purposes of filing a criminal information, are such facts as are sufficient to engender a well-
founded belief that a crime has been committed and that the accused is probably guilty thereof. It is the existence
of such facts and circumstances as would excite the belief in a reasonable mind, acting on the facts within the
knowledge of the prosecutor, that the person charged was guilty of the crime for which he is to be prosecuted. A
finding of probable cause needs only to rest on evidence showing that, more likely than not, a crime has been
committed and that it was committed by the accused.

As defined, theft is committed by any person who, with intent to gain, but without violence against, or intimidation
of persons nor force upon things, shall take the personal property of another without the latters consent. If
committed with grave abuse of confidence, the crime of theft becomes qualified. The elements of which are:

1. Taking of personal property;

2. That the said property belongs to another;
3. That the said taking be done with intent to gain;
4. That it be done without the owners consent;
5. That it be accomplished without the use of violence or intimidation against persons, nor of force upon things;
and
6. That it be done with grave abuse of confidence.

…….complete this portion…..

Ruben Del Castillo vs People of the Philippines

G.R. No. 185128
30 January 2012
Facts:
Police officers headed by SPO3 Bienvenido Masnayon secured a search warrant from the Regional Trial Court after
conducting surveillance and test-buy operation at the house of Ruben Del Castillo based on confidential
information received. The same police officers went to Del Castillo’s house to serve the search warrant. However,
someone shouted “raid” when the police officers reached the house. They went upstairs and informed the wife
that they will implement the search warrant. Before they can search the area, SPO3 Masnayon claimed that he saw
petitioner run towards a small structure, a nipa hut, in front of his house. Masnayon chased him but to no avail.
SPO3 Masnayon requested his men to get a barangay tanod and together they searched the nipa hut where Del
Castillo allegedly ran for cover. Nothing was found from Del Castillo’s house but four plastic packs containing white
crystalline substance were found in the nipa hut. The contents of the plastic packs resulted positive for the
presence of methamphetamine hydrochloride, or shabu upon laboratory examination. The Regional Trial Court
found Del Castillo guilty of violating RA 6425. The Court of Appeals affirmed the decision.

Issue:
Whether or not there was probable cause to issue the search warrant, considering that SPO1 Reynaldo Matillano,
the police officer who applied for it, had no personal knowledge of the alleged illegal sale of drugs during a test-
buy operation conducted prior to the application of the same search warrant?

Decision:
Probable cause for a search warrant is defined as such facts and circumstances which would lead a reasonably
discreet and prudent man to believe that an offense has been committed and that the objects sought in
connection with the offense are in the place sought to be searched. A finding of probable cause needs only to rest
on evidence showing that, more likely than not, a crime has been committed and that it was committed by the
accused. Probable cause demands more than bare suspicion; it requires less than evidence which would justify
conviction. The judge, in determining probable cause, is to consider the totality of the circumstances made known
to him and not by a fixed and rigid formula, and must employ a flexible, totality of the circumstances standard. The
existence depends to a large degree upon the finding or opinion of the judge conducting the examination.

The Supreme Court is in no position to disturb the factual findings of the judge which led to the issuance of the
search warrant. A magistrate's determination of probable cause for the issuance of a search warrant is paid great
deference by a reviewing court, as long as there was substantial basis for that determination. Substantial basis
means that the questions of the examining judge brought out such facts and circumstances as would lead a
reasonably discreet and prudent man to believe that an offense has been committed, and the objects in
connection with the offense sought to be seized are in the place sought to be searched. A review of the records
shows that substantial basis exists.

Iota of Evidence (Circumstancial)

People of the Philippines vs Alberto Anticamara and Fernando Fernandez
G.R. No. 178771
08 June 2011

Facts:
Conrado Estrella and his wife employed AAA and Sulpacio Abad as maid and driver respectively. Sometime on the
afternoon of 07 May 2002, the group of Fernando Fernandez (Lando), Alberto Anticamara (Al), Dick Taedo (Dick),
Roberto Taedo (Bet), Marvin Lim (Marvin), and Fred Doe entered the house of AAA’s employer whilst she was
sleeping. Thinking that the intruders left the house already, she attempted to run but Dick was still there. After a
brief commotion, the group decided to tie AAA and was led outside the house. AAA saw Abad tied and blindfolded
inside a vehicle.
AAA was brought to the fishpond, there she saw Necitas Ordeiza-Taedo (Cita). The group brought Abad outside the
vehicle and was led away. AAA heard the group discussing to make a decision since Abad apparently has been shot
four times. Later on, Lando and Fred boarded the vehicle taking AAA with them to San Miguel, Tarlac. She was kept
in Lando’s house until 09 May 2002.

On 09 May 2002, Lando told AAA that Fred and Bert has intention to kill her and he brought her to a hotel.
Through threat, Lando sexually molested AAA. Later on Fred, Bert and Lando transferred AAA to the house of
Fred’s niece in Riles, Tarlac. Fred kept AAA as a wife and repeatedly raped her at night, threatening to give her back
to Lando whom she knew killed Abad.

On 22 May 2002, Fred, together with his family, transferred AAA to Carnaga. AAA was made to stay as a house
helper in the house of Fred’s brother-in-law. On 04 June 2002, AAA escaped the house and sought help from her
friend who called AAA’s brother. Arriving Mandaue City, AAA and her brother reported the incident to police
authorities. The cadaver of Abad was autopsied and cause of death was gunshot wounds on trunk.

Lando, Al and Cita pleaded not guilty during arraignment while Dick, Bet, Marvin and Fred Doe remained at-large.

The Regional Trial Court convicted both Lando and Al for the crime of Murder and Kidnapping/Serious Illegal
Detention. Whereas Cita was found not guilty for both crimes due to insufficiency of evidence. The Court of
Appeals affirmed the decision.

Lando appealed the decision of the Court of Appeals contending that the court gravely erred in giving scant
consideration to the evidence presented by the accused-appellant which is more credible than that of the
prosecution.

Issue:
Whether or not the Court erred in finding circumstantial evidence against the accused-appellant sufficient to
convict them?

Decision:
The Supreme Court affirmed the decision of the Court of Appeals.

Circumstantial evidence consists of proof of collateral facts and circumstances from which the existence of the
main fact may be inferred according to reason and common experience.

Circumstantial evidence is sufficient to sustain conviction if:

(a) There is more than one circumstance;

(b) The facts from which the inferences are derived are proven;
(c) The combination of all circumstances is such as to produce a conviction beyond reasonable doubt.

A judgment of conviction based on circumstantial evidence can be sustained when the circumstances proved form
an unbroken chain that results in a fair and reasonable conclusion pointing to the accused, to the exclusion of all
others, as the perpetrator.

In this case, the circumstantial evidence presented by the prosecution, when analyzed and taken together, lead to
the inescapable conclusion that the appellants are responsible for the death of Sulpacio. In addition to these
circumstances, the trial court further found that AAA heard Fred utter “Usapan natin pare, kung sino ang
masagasaan, sagasaan. (Our agreement is that whoever comes our way should be eliminated).”

Moreover, NBI Agent Gerald V. Geralde testified that on June 23, 2002, appellant Al admitted his participation as
lookout and naming his companions Dick, Lando, Fred, Marvin and Bet as the ones who took AAA and Sulpacio
from the house of the Estrellas and brought them to the fishpond. Al also pointed and led the authorities to a
shallow grave in Sitio Rosalia, Barangay San Bartolome, Rosales, Pangasinan, where the remains of Sulpacio were
buried. The autopsy conducted on the body, prepared by the Medico Legal Officer Dr. Bandonil, shows that several
holes were found on various parts of the body of the victim and Dr. Bandonil concluded that the cause of the
victim's death was the gunshot wounds. The report also indicates that a piece of cloth was found wrapped around
the eye sockets and tied at the back of the skull, and another cloth was also found tied at the remnants of the left
wrist.

In the case at bar, although no one directly saw the actual killing of Sulpacio, the prosecution was able to paint a
clear picture that the appellants took Sulpacio away from the house of the Estrellas, tied and blindfolded him, and
brought him to another place where he was repeatedly shot and buried.

People of the Philippines vs Maritess Alolod, Efren Deocampo, Elmer Deocampo and Edwin Deocampo
G.R. No. 185212
15 February 2012

Facts:
Melanio and Lucena Alolod adopted Maritess Alolod. Maritess had two children with her lover, Efren Deocampo,
who was never allowed to set foot on her parents house since they loathed him. On May 1998 the old couple went
missing.

Demetrio Nebit, security guard of the school next to the Alolod’s house, saw Efren and his brother Edwin standing
near the fence on the evening of 27 May 1998. The following day, Victor Ato from the neighboring house heard
strange sounds coming from the house. Waking up later, he saw Efren at the kitchen of the Alolod’s house.
Magadalena Ato, wife of Victor, got the chance to speak to Maritess and the latter explained that her parents went
to Cotabato City.

The fence where Efren and Edwin stood were cut. Annaliza Relles, the grandniece of the Alolods, tried to use one
of the toilets during her visit and it was padlocked. She was told that the old couple went for a vacation. Generita
Caspillo noticed a pile of red soil near the well at the garden. During the town fiesta Maritess informed those who
asked her that her parents went to Davao. On another visit, Generita saw Efren wearing Melanio’s watch. Relatives
growing concern led to Francisco Estaris and Joel Relles, relatives, to search the house for clues. Francisco noticed
a portion of the land planted with camote. Francisco found the place unlikely for camote since it was shaded from
the sun. Those who boarded at the house said that it was Maritess and Efren who planted them. With the help of
others, Francisco dug up the suspected spot. There they found the decomposing bodies of Melanio and Lucena.

The Regional Trial Court found the four accused guilty of murder of the old couple, with Efren and Edwin as
principals and Maritess and Elmer as accessories. Maritess and Elmer withdrew their appeal. The Court of Appeals
affirmed the lower court’s decision.

Issue:
Whether or not the court erred in finding that Efren was responsible for the murder of the Alolod couple based on
circumstantial evidence?

Decision:
The Supreme Court affirmed the decision. The circumstances constitute an unbroken chain that inexorably leads to
one fair conclusion that the accused committed the crime to the exclusion of all others.

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
produce a conviction beyond reasonable doubt.
The alibi of Efren that he was in Maguindanao at about the time the old couple was killed does not encourage
belief. The security guard saw him with his brother at 8:30 p.m. of 27 May near the Alolod’s house where they had
no business being there. Victor Ato saw Efren at the kitchen of that house on the morning following the slaying of
the couple. It was not physically impossible for the accused to be at the crime scene when it happened.