REMEDIAL LAW: EVIDENCE

PEOPLE OF THE PHILIPPINES v HERNANDO BONGOS

G.R. No. 227698, January 31, 2018, SECOND DIVISION
(PERALTA, J.)
DOCTRINE:
A judgment of conviction based on circumstantial evidence can be sustained
when the circumstances proved form an unbroken chain that results in a fair and
reasonable conclusion pointing to the accused, to the exclusion of all others, as the
perpetrator.
FACTS:
AAA, helper of BBB and CCC, was left to tend the house when CCC went to her
mother's house. While AAA was washing dishes, two male persons entered the house
through the kitchen. She identified them as Bongos, the one wearing bonnet up to his
forehead, and Dexisne, the one wearing black short pants with red stripes on the side.
Bongos pointed a gun at her, while Dexisne pointed his knife. They forced her to
enter the room where the money of her employer was and demanded her to open the
drawer. After they took the money, they forcibly dragged AAA outside. There, armed
with a knife and gun, both accused threatened and ordered AAA to undress herself.
When she refused to do so, Dexisne got violent and slashed her leg and then hit her
chest near her left breast which caused her to lose consciousness. When AAA woke
up, she no longer had her clothes on and felt pain on her private part.
ISSUE:
Can an accused be found guilty beyond reasonable doubt on the basis of
circumstantial evidence?
RULING:
Yes. Circumstantial evidence, also known as indirect or presumptive evidence,
refers to proof of collateral facts and circumstances when the existence of the main
fact may be inferred according to reason and common experience. Circumstantial
evidence is sufficient to sustain conviction if (a) there is more than one circumstance;
(b) the facts from which the inferences are derived are proven; (c) the combination of
all circumstances is such as to produce a conviction beyond reasonable doubt.
In this case, the prosecution presented circumstantial evidence that when
analyzed and taken together, lead to the obvious conclusion that Bongos and Dexisne
also raped AAA on the occasion of the robbery: first, after appellant took the money,
they forcibly dragged AAA outside of the house’s fence; second, appellant forced AAA
to undress; third, when AAA refused, co-accused Dexisne got mad and hit her at her
chest causing her to lose consciousness; fourth, when AAA regained consciousness,
AAA had no longer clothes on; and fifth, she felt pain in her private part.
Therefore, the accused can be found guilty beyond reasonable doubt on the
basis of circumstantial evidence.