PEOPLE v.

LARA Even in the absence of direct evidence, conviction can be had if

Circumstantial Evidence | August 12, 2012 | Reyes, J. the established circumstances constitute an unbroken chain,
SUMMARY: consistent with each other and to the hypothesis that the accused
Sumulong and some others were on the way back to San is guilty, to the exclusion of all other hypothesis that he is not.
Sebastian Allied Services Inc after withdrawing payroll money to
be defrayed to the companys employees when, at the intersection Requirements for circumstantial evidence to obtain a conviction:
of Mercedes and Market Avenue in Pasig City, Lara suddenly a. There is more than one circumstance
appeared on the front passenger side of the car and asked for the b. The facts from which the inference is drawn is proven
bag which contained the payroll money amounting to P230,000. c. Combination of all the circumstances is such as to prove
When Bautista (Sumulongs company) obtained the bag after a conviction beyond reasonable doubt
advising him not to give it to Lara, he ran and was subsequently
allegedly shot and killed by Lara who obtained the money bag. [Plopis note: The bullet points in Sumulongs testimony are the
Lara is now assailing the decision of the RTC and CA that same circumstances the Court declared the circumstances that
convicted him of robbery with homicide, stating that there was not supported the inference that Lara was the one who shot Bautista.
enough evidence to support the conviction because it was based Circumstancial evidence that was enough to obtain a condition.]
on mere circumstantial evidence. (Proceed to Ratio for SC
decision) Other issues not relevant:
WoN the positive identification of Lara by Sumulong in the
FACTS: police line-up without the assistance of counsel was admissible
SUMULONGs TESTIMONY: YES
- Sumulong, an accounting staff of San Sebastian Allied The right to counsel is deemed to have arisen at the precise
Services, withdrew the amount of P230,000 from moment custodial investigation begins and being made to stand in
Metrobank-Mabini Branch, Pasig City to defray the a police line-up is not the starting point or a part of custodial
salaries of the employees of San Sebastian investigation
- In going to the bank, he rode a pick-up and was
accompanied Bautista and some others. WoN his alibi checked out NO
- He placed the amount withdrawn in a black bag and It was not shown that he was far away enough to render it
immediately left the bank. impossible for him to be at the scene of the crime when it
- While they were at the intersection of Mercedes and happened. The proximity of his house to the crime scene negates
Market Avenue, Pasig City, Lara suddenly appeared at his alibi.
the front passenger side of the pick-up and pointed a gun
at him (Sumulong) and asked for the black money bag. DISPOSITIVE PORTION:
- Bautista, at the back of the car, told Sumulong not to
give the back and heeding his advice, Sumulong threw In fine, the assailed decision of the CA is affirmed in all respects.
the bag to his direction. With the bag, Bautista alighted
the vehicle and ran. Lara ran after him. WHEREFORE, premises considered, the Decision dated July 28,
- Sumulong got out of the pick-up and reported the 2011 of the Court of Appeals in CA-G.R. CR HC No. 03685 is
incident to his company. When he got back to the car, he hereby AFFIRMED.
saw blood and a bystander told him Bautista was shot SO ORDERED.
and the bag was taken.
- The investigators found blood on the crime scene,
Bautistas body sustained several gunshot wounds, and
they also recovered empty shells from the crime scene.
LARAs DEFENSE:
- His alibi: he was working with his brother in digging a
sewer trench at San Miguel Pasig City
- There was not enough direct evidence to obtain a
conviction because there was no eyewitness. He asserts
that Sumulong could not have properly seen him shoot
Bautista.
Both RTC and CA convicted him of robbery with homicide.

ISSUE/S & RATIO:

WoN circumstantial evidence may be used to obtain a
conviction YES

Well-settled is the rule that direct evidence of the commission

of the crime is not the only matrix wherefrom a trial court
may draw its conclusion and finding of guilt.

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