People v.

Padua | February 23, 2007 Facts: Christopher Padua, Alejandro Padua and Michael Dullavin were charged with rape with homicide of a 10 year old minor XXX. XXXs younger brothers YYY and ZZZ testified that they saw the three carry their older sister away while they were walking home in Muntinlupa and that her mouth was covered to keep her from crying out. They were able to positively identify the three suspects because the place where XXX was taken from was illuminated by billboard lights. XXX was found dead 2 days later in Pacita Complex, San Pedro, Laguna, with her clothes strewn around her body. An examination of the body found that XXX was raped. The three interposed an alibi that they were in Alabang when the incident took place. The lower court found the three guilty, and sentenced them to death. Later on it was found that Christopher was a minor at the time of the crime, and his sentence was reduced to reclusion perpetua. Alejandros sentence was also reduced to reclusion perpetua since he was already 72 years old at the time of the commission of the crime. Issue: WON the guilt of the three accused was proven beyond reasonable doubt. Held: YES. Direct evidence of the commission of a crime is not the only matrix wherefrom a trial court may draw its conclusion and finding of guilt. The rules of evidence allow a trial court to rely on circumstantial evidence to support its conclusion of guilt. Circumstantial evidence is that evidence which proves a fact or series of facts from which the facts in issue may be established by inference. Section 4 of Rule 133 of the Rules of Court provides that circumstantial evidence is sufficient for conviction if the following requisites are complied with: (1) there is more than one circumstance; (2) the facts from which the inferences are derived are proven;

and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. All the circumstances must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with the hypothesis that he is innocent. Thus, conviction based on circumstantial evidence can be upheld, provided the circumstances proven constitute an unbroken chain which leads to one fair and reasonable conclusion that points to the accused, to the exclusion of all others, as the guilty person. In this case, all the circumstantial evidence that were presented have been duly proven and established. the prosecution was able to establish the appellants culpability through the established facts which constitute an unbroken chain of events leading to the conclusion of guilt on the part of the appellants. There is thus moral certainty that they authored the crime charged. And even though the appellants contended that the witnesses were not credible, the court found their narration of the events to be consistent even after rigorous cross examination by 3 defense counsels. Lastly, their alibi did not hold up, as they were not able to show that it was physically impossible for them to be at the scene of the crime at the time of its commission.