Salvador v People Digest

Facts:
Petitioner Nover Salvador was charged with homicide at the RTC of Valenzuela for
allegedl !illing his sister"in"law #rlene $u%iga The RTC rendered a decision &nding
petitioner guilt of homicide 'ased on the following circumstantial evidence:
() the non"emploment of force in entering the scene of the crime which
implied that the perpetrator is an occupant of the house* the accused was+
during the time material to this case+ residing with his in"laws*
,) no missing personal 'elongings*
-) the a'sence of 'loodstains in other parts of the house e.cept #rlene/s
room*
0) petitioner/s ownership of a 'alisong+ the same weapon used in sta''ing
the victim*
1) the presence of tpe 232 human 'lood on petitioner/s T"shirt and 'riefs*
4) the positive result of the DN# analsis using the 'loodstains found in
petitioner/s shirt and 'riefs* and
5) petitioner/s unusual 'ehavior after the discover of the victim/s lifeless
'od6
3n appeal+ the C# a7rmed the decision of the lower court6 8ence+ this petition6
9ssue: :hether or not the circumstantial evidence used ' the lower court was
su7cient to convict petitioner
8eld:
Prior to the fateful night when #rlene/s lifeless 'od was discovered+ several
witnesses saw petitioner in possession of a 'alisong6 The N;9 autops report+ in
turn+ stated that the wounds sustained ' #rlene were in<icted with the use of a
weapon onl one side of which was sharp =such as a 'alisong)6 #fter the discover
of the crime+ the 'alisong was nowhere to 'e found6 8ence+ the trial court was
correct in its conclusion that the 'alisong previousl seen in petitioner/s possession
was the ver weapon used in sta''ing the victim6 :hile petitioner admitted owning
a di>erent !ind of weapon+ he failed to produce it in court6 #s such+ it remained a
self"serving allegation that cannot 'e considered to e.onerate him from lia'ilit6
#s to petitioner/s shirt and 'riefs+ as correctl held ' the trial court =and as
a7rmed ' the appellate court)+ the were found to 'e stained with tpe 232 'lood
=the victim/s 'lood tpe)6 9nstead of ?uestioning the a'sence of proof that he was
not of the same 'lood tpe as the victim+ petitioner should have presented evidence
that he indeed has tpe 232 'lood6 The fact remains that petitioner o>ered no
e.planation wh his shirt and 'riefs contained 'loodstains6 9t is+ therefore+ correct to
conclude that the were stained with the victim/s 'lood6
9ntent to !ill was dul esta'lished ' the witnesses when the testi&ed relative to
the 2peeping incident62 #lthough there was no evidence or allegation of se.ual
advances+ such incident manifested petitioner/s evil motive6 @otive and intent ma
'e considered one and the same+ in some instances+ as in the present case6
Aastl+ the DN# analsis made ' the N;9 e.pert placed the petitioner at the scene
of the crime6 Such evidence was considered+ together with the other circumstances
discussed earlier6 The individual pieces of evidence ma not 'e su7cient to point to
the accused as the author of the crime6 8owever+ when ta!en together+ the are
more than enough to esta'lish 'eond reasona'le dou't that petitioner committed
the crime of homicide6 :e would li!e to emphasize at this point that the peculiarit
of circumstantial evidence is that the guilt of the accused cannot 'e deduced from
scrutinizing Bust one particular piece of evidence6 9t is more li!e a puzzle which+
when put together+ reveals a remar!a'le picture pointing towards the conclusion
that the accused is the author of the crime6