People of the Philippines vs. John Sanota, Deo Dayto, et.al.

G.R. No. 233659 (December 10, 2019)

Peralta, C, J.:

DOCTRINE

Direct evidence of the commission of a crime is not the only basis on which a
court draws its finding of guilt. The commission of a crime, the identity of the
perpetrator, and the finding of guilt may all be established by circumstantial
evidence.

No general rule can be laid down as to the quantity of circumstantial evidence

which in any case will suffice. All the circumstances proved 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, and with every
other rational hypothesis except that of guilt.

FACTS

Accused planned to rob the house of Quiros which was overheard by Abios in his
backyard. On the day of the execution of the accused’s plan, one of the accused invited
Abios, the witness in this case, to accompany him to a birthday party, which turned out
to be untrue. Abios found himself near the Quiros residence and saw one of the accused
handed a firearm to Dayto who entered Quiros’ residence. 5 minutes thereafter, Abios
saw Dayto coming out of the window and holding a black thing in his left and a gun in
his right. A day after the incident. Abios heard the news that Miguel Quiros was shot in
his house causing his death. Being afraid, Abios kept his mouth shut until he was
persuaded by his wife to testify. RTC convicted all of the accused of the crime of
Robbery with Homicide. Feeling aggrieved, accused appealed before the Supreme Court
arguing that the lower court erred in giving credence to Abios’ testimony as there was
no direct evidence proving that Dayto actually shot Miguel. And that all of the pieces of
evidence presented by the prosecution were mere circumstantial evidence.
ISSUE

Whether Abios’ testimony is enough to convict all of the accused.

RULING

Yes.

As to the contention of appellants that the prosecution failed to present any direct
evidence that proves their participation in the commission of the crime, such does not
deserve merit. Direct evidence of the commission of a crime is not the only basis on which a
court draws its finding of guilt. The commission of a crime, the identity of the perpetrator,
and the finding of guilt may all be established by circumstantial evidence. The difference
between direct evidence and circumstantial evidence involves the relationship of the fact
inferred to the facts that constitute the offense. Their difference does not relate to the
probative value of the evidence. Direct evidence proves a challenged fact without drawing
any inference. Circumstantial evidence, on the other hand, "indirectly proves a fact in
issue, such that the fact-finder must draw an inference or reason from circumstantial
evidence. A number of circumstantial evidence may be so credible to establish a fact from
which it may be inferred, beyond reasonable doubt, that the elements of a crime exist and
that the accused is its perpetrator.