438 Phil.

716

EN BANC
[ G.R. No. 146689, September 27,
2002 ]
PEOPLE OF THE PHILIPPINES, PLAINTIFF-
APPELLEE, VS. FERNANDO (FERDINAND) MONJEY
ROSARIO @ FERNAN, LORDINO (BERNARD)
MAGLAYA Y ALVAREZ @ ODENG (ACQUITTED),
CHRISTOPHER BAUTISTA Y ROSARIO @ TOTDE
(ACQUITTED), AND MICHAEL CASTRO Y OSIAS @
IKING (ACQUITTED), ACCUSED. FERNANDO
(FERDINAND) MONJE Y ROSARIO @ FERNAN,
ACCUSED-APPELLANT.

DECISION

BELLOSILLO, J.:

In assaying the probative value of circumstantial evidence, four (4)

basic guidelines must be observed: (a) It should be acted upon with
caution; (b) All the essential facts must be consistent with the
hypothesis of guilt; (c) The facts must exclude every other theory but
that of guilt of the accused; and, (d) The facts must establish with
certainty the guilt of the accused as to convince beyond reasonable
doubt that he was the perpetrator of the offense. The peculiarity of
circumstantial evidence is that the series of events pointing to the
commission of a felony is appreciated not singly but collectively. The
guilt of the accused cannot be deduced from scrutinizing just one (1)
particular piece of evidence. It is more like a puzzle which when put
together reveals a convincing picture pointing to the conclusion that
the accused is the author of the crime.[18]

Under the rules, circumstantial evidence is sufficient to convict an

accused if the following requisites concur: (a) There is more than one
circumstance; (b) The facts from which the inferences are derived are
proved; and, (c) The combination of all the circumstances is such as to
produce a conviction beyond reasonable doubt.

Circumstantial evidence finds application in crimes such as rape with

homicide. The nature of the crime of rape, where usually only the
victim and the rapist are present at the crime scene, makes
prosecutions for the complex crime of rape with homicide particularly
difficult since the victim can no longer testify against the perpetrator of
the crime.[19] Circumstantial evidence must form a complete and
unbroken chain which, taking the evidence as a whole, leads directly
to the guilt of the accused beyond reasonable doubt excluding any
reasonable inference other than that of guilt.

[18]
People v. Licayan, G.R. No. 144422, 28 February 2002.

[19]
Id.

454 Phil. 728

EN BANC
[ G.R. No. 132218, July 24, 2003 ]
PEOPLE OF THE PHILIPPINES, APPELLEE, VS. JOSE
NAVARRO, JR., APPELLANT.

While it is established that nothing less than proof beyond reasonable

doubt is required for a conviction, this exacting standard does not
preclude resort to circumstantial evidence when direct evidence is not
available. Direct evidence is not a condition sine qua non to prove the
guilt of an accused beyond reasonable doubt. For in the absence of
direct evidence, the prosecution may resort to adducing circumstantial
evidence to discharge its burden.[40] Crimes are usually committed in
secret and under conditions where concealment is highly probable. [41]
If direct evidence is insisted on under all circumstances, the
prosecution of vicious felons who commit heinous crimes in secret or
secluded places will be hard, if not impossible, to prove.[42]

Here, the trial court relied on circumstancial evidence in finding

appellant guilty of the crime charged.

Circumstantial evidence has been defined as that which indirectly

proves a fact in issue.[43] To be sufficient for conviction, Sec. 4 of Rule
133 of the Rules of Court provides that the following requisites must
concur:

(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.
Also, jurisprudence requires that the circumstances must be
established to form an unbroken chain of events leading to one fair
reasonable conclusion pointing to the accused, to the exclusion of all
others, as the author of the crime.[44]
Reviewed in light of the requirements set forth in Sec. 4, Rule 133, as
well as established jurisprudence, we find no reason to depart from the
findings of the trial court. There was more than one circumstance
relied upon, the facts from which the inferences were derived were
proven, and the combination of all the circumstances was such as to
produce a conviction of the appellant beyond reasonable doubt to the
exclusion of all others.
[40]
People vs. Santiago, G.R. No. 133445, February 27, 2003.

[41]
People vs. Roa, 167 SCRA 116, 122 (1988).

[42]
People vs. Casitas, Jr., G.R. No. 137404, February 14, 2003.

[43]
People vs. Fabon, G.R. No. 133226, 328 SCRA 302, 316 (2000).

[44]
People vs. Rosario, et al., G.R. No. 146689, September 27, 2002.

[45]
People vs. Delim, G.R. No. 142773, January 28, 2003.