I.

THE MAIN ISSUE AND THE APPLICABLE LAW

The principal issue in this case is whether or not the accused is guilty
of qualified theft, penalized under Article 310 in relation to Articles 308 and
309 of the Revised Penal Code.

Section 14, Article III of the 1987 Philippine Constitution demands that
every accused shall be presumed innocent until the contrary is proved.

In consonance with this constitutional provision, the burden of proof

rests upon the prosecution, and the accused must then be acquitted and set
free should the prosecution not overcome the presumption of innocence in
his favor. Conversely, in convicting the accused all the elements of the crime
charged must be proven beyond reasonable doubt. Thus, the rule provides:

Sec. 2. Proof beyond reasonable doubt. -  In a criminal case, the

accused is entitled to an acquittal, unless his guilt is shown beyond
reasonable doubt. Proof beyond reasonable doubt does not mean
such a degree of proof as, excluding possibility of error, produces
absolute certainty. Moral certainty only is required, or that degree of
proof which produces conviction in an unprejudiced mind. 1

This rule places upon the prosecution the task of establishing the guilt
of an accused, relying on the strength of its own evidence, and not banking
on the weakness of the defense of an accused. Requiring proof beyond
reasonable doubt finds basis not only in the due process clause of the
Constitution, but similarly, in the right of an accused to be "presumed
innocent until the contrary is proved”. Undoubtedly, it is the constitutional
presumption of innocence that lays such burden upon the prosecution.
Should the prosecution fail to discharge its burden, it follows, as a matter of
course, that an accused must be acquitted.2

It is a settled rule that circumstantial evidence is sufficient to support

a conviction, and that direct evidence is not always necessary. The lack or
absence of direct evidence does not necessarily mean that the guilt of the
accused cannot be proved by evidence other than direct evidence. Direct
evidence is not the sole means of establishing guilt beyond reasonable
doubt, because circumstantial evidence, if sufficient, can supplant the
absence of direct evidence.3 Circumstantial evidence is that evidence that
proves a fact or series of facts from which the fact in issue may be
established by inference. It may be resorted to when to insist on direct
testimony would ultimately lead to setting felons free. 4

According to Section 4, Rule 133 of the Rules of Court, 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.” Thus, conviction based on
circumstantial evidence can only be upheld provided that the circumstances
proven constitute an unbroken chain which leads to one fair and reasonable

1 Rule 133, Section 2 of the Revised Rules on Evidence.

2 Nilo Macayan, Jr. y Malana, vs. People, G.R. No. 175842, March 18, 2015.
3 People vs. Jeffrey Lignes y Papillero, G.R. No. 229087, June 17, 2020.
4 Celerino Chua alias Suntay, vs. People, G.R. No. 172193, September 13, 2017.
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People vs. Sagun
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conclusion that points to the accused, to the exclusion of all others, as the
guilty person. 5

5 Jose Espineli vs. People, G.R. No.179535, June 9, 2014.