“In criminal cases, circumstantial evidence, if sufficiently proven, can produce the conviction of the accused”
To understand circumstantial evidence there is a need to define the word circumstance.
Circumstances are facts or conditions connected with or are relevant to an event or action (Oxford Dictionary). Circumstantial evidence therefore relates to a series of facts, other than the fact in controversy or in dispute, from which inferences may be derived.
On the other hand, direct evidence is evidence which, if believed, proves the existence of the fact in issue, without any inference or presumption (Evidence, Francisco citing 31 Corpus Juris Secundum 505).
Examples include the eyewitness account of someone who witnessed the stabbing of a victim, or the injured party who was frontally shot by the accused.
In criminal cases, circumstantial evidence, if sufficiently proven, can produce the conviction of the accused.
Only the presence of multiple circumstances will warrant a conviction assuming that each of the facts (or circumstances) from which the inferences are drawn is proven (see Section 4, Rule 133, 2019 Amended Rules on 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… inconsistent with the hypothesis that he is innocent…”(Evidence, Francisco citing People v. Ludday, 61 Phil. 216).
The commission of a crime, the identity of the perpetrator, and the finding of guilt may all be established by circumstantial evidence.
The circumstances must be considered as a whole and should create an unbroken chain leading to the conclusion that the accused authored the crime (Bacerra v. People, G.R. No. 204544, July 03, 2017).
While there is no conviction in civil cases, liability may be determined by considering “all the facts and circumstances of the case, the witnesses’ manner of testifying, their intelligence, their means… of knowing the facts…,” among others; and all of these contribute to a preponderance of evidence (Section 4, Rule 133, 2019 Amended Rules on Evidence).
In the case of Bacerra v. People, no one saw petitioner [Bacerra] actually set the nipa hut on fire.
Nevertheless, the prosecution has established multiple circumstances, which, after being considered in their entirety, support the conclusion that petitioner is guilty beyond reasonable doubt of simple arson (G.R. No. 204544, July 03, 2017).
First, the evidence was credible and sufficient to prove that the petitioner stoned the private complainant’s house and threatened to burn him.
Second, the evidence was credible and sufficient to prove that petitioner returned a few hours later and made his way to the private complainant’s nipa hut (Bacerra v. People, G.R. No. 204544, July 03, 2017).
Third, the evidence was also credible and sufficient to prove that the petitioner was in close proximity to the nipa hut before it caught fire.
The private complainant testified that he saw the petitioner (Bacerra) walk to and fro in front of the nipa hut and shake its posts just before it caught fire (G.R. No. 204544, July 03, 2017).
Circumstantial evidence is like a “tapestry made up of strands which create a pattern when interwoven.”
Each strand cannot be plucked out and scrutinized individually because it only forms part of the entire picture (G.R. No. 204544, July 03, 2017).
In another case, the Supreme Court affirmed the findings of the trial court that “circumstantial evidence proven by the prosecution sufficiently established that appellant committed the offense (robbery with homicide) charged.”
There should be a combination of evidence which, in the ordinary and natural course of things, leaves no room for reasonable doubt as to his guilt (People v. Lignes, G.R. No. 229087, June 17, 2020).
Based on the records, Lignes asked Jayson of the location of Laurora’s house.
Lignes then went to the latter’s house, where witnesses heard the shouting and moaning from Laurora’s house and where a witness noticed somebody waving a flashlight inside Laurora’s house, as if looking for something.
They also noticed that the water coming out of the drainage was brownish, as if mixed with blood (People v. Lignes, G.R. No. 229087, June 17, 2020).
It was also proven that Lignes, wearing a black t-shirt and carrying a backpack full of Laurora’s personal belongings rushed out of Laurora’s house.
Lignes was also frisked and a screwdriver was found in his possession; it was later proven that Laurora’s death was due to multiple stab wounds.
A witness also identified the green shirt worn by the child offender (co-conspirator of Lignes) as Laurora’s (People v. Lignes, G.R. No. 229087, June 17, 2020).
However, in the case of People v. Cadenas and Martije, the Supreme Court reversed the conviction of Cadenas and Martije for rape with homicide which was based on circumstantial evidence.
The trial court and Court of Appeals “rushed to the conclusion that the presence of the appellants at the crime scene…as sufficient to incriminate them to the commission of the crime charged” (G.R. No. 233199, November 05, 2018).
The circumstance of being at the scene of the crime and leaving hastily may raise speculations, as it had, in fact, inevitably made Cadenas and Martije the prime suspects, but it is far too inadequate to support a conviction.
The Court has consistently stressed that mere suspicions and speculations can never be the bases of conviction in a criminal case (G.R. No. 233199, November 05, 2018).
The testimony of witness Escribano was highly suspicious, and it was contrived to pin criminal culpability upon Cadenas and Martije.
No shred of evidence is on record that could show the existence of a source of light then which may have provided Escribano with enough illumination that enabled him to recognize who the two persons were (G.R. No. 233199, November 05, 2018).
It is strange that Escribano should return to Castillo (live-in partner of the victim) when natural instinct and reason would dictate that he should have entered the house to see if anything bad happened to his friend’s live-in partner or should have at least called for the victim’s name from outside the house to check on her condition.
His reaction was unnatural and contrary to ordinary human experience (G.R. No. 233199, November 05, 2018).
The Supreme Court finds it disturbing how Barangay Captain Gerald Arquiza (Arquiza) was able to identify Cadenas and Martije as the sexual ravishers and killers of AAA (the victim).
Nowhere in the prosecution’s evidence does it show that Castillo and/or Escribano reported the incident and that they had identified the perpetrators to Arquiza at any time after the discovery of the body of the victim (G.R. No. 233199, November 05, 2018).
Finally, there is a paucity of evidence to show that the appellants (Cadenas and Martije) have a motive to rape or kill the victim.
There was also no evidence that Cadenas and Martije carried a grudge or had an axe to grind against the victim or her live-in partner, Castillo. In fact, Cadenas declared that he did not find AAA attractive (G.R. No. 233199, November 05, 2018).
The Supreme Court underscored that a conviction must be based on the strength of the prosecution’s evidence and not on the weakness of the evidence of the defense.
It is paramount that the prosecution proves the guilt of the accused and not the accused to prove his innocence.
The prosecution’s circumstantial evidence fails to prove indubitably the appellants’ commission of the crime of rape with homicide (G.R. No. 233199, November 05, 2018).