People v Chavez

G.R. No. G.R. No. 207950, Date: September 22, 2014

FACTS:
Respondent Mark Jason Chavez was charged with the crime of robbery with homicide upon the
person of Elmer Duque. One of prosecution witness, Angelo Peñamante, testified that arriving
home at 2:45 a.m., he saw the accused leaving the house of the victim, which is just six meters
across his own and that at 11:00 a.m. of the same day, he was informed that Duque was found
dead in his house. A week after the incident, Chavez, accompanied by his mother, surrendered
to the police. Chavez explained that he went to Duque’s home at around 1:00 a.m. to talk about
their misunderstanding and then left after.
The trial court found Chavez guilty of the crime of Robbery with Homicide. On appeal, the Court
of Appeals affirmed the decision of the trial court.
Chavez contends that since the prosecution relied on purely circumstantial evidence, conviction
must rest on a moral certainty of guilt on his part but Peñamante only saw him leaving Duque’s
house but did not specify whether he was acting suspiciously.

ISSUE/S:
Can Chavez’s guilt be proven only through circumstantial evidence?

RULING:
1. Yes. The Court ruled that the Rules of Court expressly provides that circumstantial evidence
may be sufficient to establish guilt beyond reasonable doubt for the conviction of an accused.
Section 4, Rule 133 of the Rules of Court provides that circumstantial evidence is sufficient for
conviction if: (a) There is more than one circumstance; (b) The facts from which the inferences
are derived are proven; and (c) The combination of all the circumstances is such as to produce
a conviction beyond reasonable doubt. Factual findings by the trial court on its appreciation of
evidence presented by the parties, and even its conclusions derived from the findings, are
generally given great respect and conclusive effect by this court, more so when these factual
findings are affirmed by the Court of Appeals.
However, the Court finds that the circumstantial evidence sufficiently proves beyond reasonable
doubt that Chavez is guilty of the crime of homicide, and not the special complex crime of
robbery with homicide.

MISC: Section 4, Rule 133 of the Rules of Court has been amended. However, the requisites
are still the same. The Revised Rule only adds as last paragraph that “inferences cannot be
based on other inferences.”