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PEOPLE V. FRONDA
G.R. No. 130602. March 15, 2000.
Direct Evidence v. Circumstantial Evidence

Facts:
Three students were convicted of violating the Dangerous Drugs Act after they allegedly delivered a brick of marijuana to
policemen who posed as buyers.

Issue: Whether or not circumstantial evidence would be sufficient for conviction

Held:
To be caught flagrante delicto necessarily implies positive identification by the eyewitness or eyewitnesses. Such is a direct
evidence of culpability, which is that which proves the fact in dispute without the aid of any inference or presumption, in
contrast to circumstantial evidence, which is the proof of facts from which taken collectively the existence of the particul ar
fact in dispute may be inferred as a necessary or probable consequence. Circumstantial evidence, however, is not a
weaker form of evidence vis-a-vis direct evidence, for our rules make no distinction between direct evidence of fact and
evidence of circumstances from which the existence of a fact may be inferred.

No greater degree of certainty is required when the evidence is circumstantial than when it is direct; for in either case, the
trier of fact must be convinced beyond reasonable doubt of the guilt of the accused.

Under the Rules of Court, circumstantial evidence would be sufficient for conviction if the following concur:
(a) there is more than one circumstance;
(b) the facts from which the inferences are derived are proved; and
(c) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

Or, as jurisprudentially formulated, a judgment of conviction based on circumstantial evidence can be upheld only if the
circumstances proven constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the
accused, to the exclusion of all others, as the guilty person, i.e., the circumstances proven must be consistent with each
other and consistent with the hypothesis that the accused is guilty.