People v.
Padua | February 23, 2007 and (3) the combination of all the
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;
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.