PEOPLE V.

LARA
G.R. No. 199877, 13 August 2013

FACTS: Three witnesses, Sumulong, SPO1 Cruz, and PO3 Calix, testified for the prosecution.
Sumulong, an accounting staff of San Sebastian Allied Services, Inc., testified that he
withdrew P230,000.00 from a bank to pay employee salaries, was robbed at
gunpoint, and positively identified Lara as the perpetrator. SPO1 Cruz testified
about Lara's arrest, and PO3 Calix provided details about the crime scene and
investigation. In his defense, Lara claimed to have been at his house during the
incident, working on a sewer trench. He presented witnesses to support his alibi,
including a neighbor and his sister.

RTC Ruling: However, the Regional Trial Court (RTC) convicted Lara of robbery
with homicide, rejecting his alibi defense. The court emphasized that for an alibi to
prosper, the accused must show that it was physically impossible for them to be at
the crime scene at the time of the crime.

CA Ruling: Lara's appeal pointed out errors in his arrest without a warrant and the
failure of his alibi defense. The Court of Appeals (CA) affirmed Lara’s conviction,
stating that the belated invocation of his illegal arrest and the failure of his alibi did
not justify setting aside the conviction. The CA also found that Lara’s alibi failed to
convince, and the evidence sufficiently established his culpability.

ISSUE: Whether or not there is sufficient evidence to convict Lara.

HELD: Yes. The Court of Appeals (CA) based its finding of guilt against Lara on
circumstantial evidence, which is a valid form of proof in criminal cases. The CA
correctly applied the legal requirements for conviction based on circumstantial
evidence, as outlined in Section 4, Rule 133 of the Revised Rules on Criminal
Procedure, which provides thatcircumstantial evidence sufficed to convict upon the
concurrence of the following requisites: (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.

The CA ruled that the established circumstances strongly indicated Lara’s guilt,
meeting the requisites for conviction based on circumstantial evidence. The CA
emphasized that in cases of robbery with homicide, the intent to gain must be
established beyond reasonable doubt, and the use of violence must be necessary to
realize such intent. Lara's intent to gain and resort to violence were proven by the
positive testimony of the witness, Sumulong. Additionally, the CA noted that the
incident took place in broad daylight, enhancing the credibility of the witness's
assertions regarding the identity of the perpetrator.
 PEOPLE V. OCHATE
G.R. No. 127154, 30 July 2002

FACTS: Around 5:15 in the afternoon of September 26, 1994, Rowena Albiso and her older
brother Roseller were walking home from school in Tampilisan, Zamboanga del
Norte. Rowena stopped at the communal water pump, while Roseller continued
home. When their father, Romulo, inquired about Rowena's whereabouts, Roseller
informed him that she had not yet returned. Romulo and Roseller searched for
Rowena and, with the assistance of barangay officials and residents, found her
lifeless body the following morning in a rice field near the accused Roldan Ochate's
house. The medico-legal officer determined that Rowena died from deep and
penetrating incised wounds. Suspecting Ochate, the police and barangay members
attempted to locate him, and he was eventually taken into custody by a member of
the CAFGU on September 29, 1994.

In his defense, Ochate asserted that he had no knowledge of the rape and killing of
Rowena Albiso. He claimed that on the afternoon of September 26, 1994, he was at
his residence, sleeping, and later went to gather tuba and tend to his copra drier.
He stated that he did not notice any unusual incident that night and was arrested
without being informed of the reasons. The appellant's confessions to law
enforcement officers were deemed inadmissible due to constitutional violations.

ISSUE: Whether or not the trial court erred in convicting Ochate based on circumstantial
evidence.

HELD: Yes. The Court emphasized the requisites for sustaining a conviction based on
circumstantial evidence and the need for caution in its appreciation. The
prosecution presented various circumstances, including the accused's presence
near the victim's house, his indifference to the search for the missing girl, and the
proximity of the victim's cadaver to the accused's hut. However, the Court found
that these circumstances were insufficient to lead to a fair and reasonable
conclusion of the accused's guilt beyond a reasonable doubt.

The Court highlighted that mere suspicion, no matter how strong, is not sufficient
to sustain a conviction, and the constitutional presumption of innocence demands
proof beyond reasonable doubt. The Court also noted that the accused's passive
reaction and his confessions to law enforcement officers were obtained in violation
of his constitutional rights, rendering them inadmissible as evidence against him.
 PEOPLE V. QUITOLA
G.R. No. 200537, 13 July 2016

FACTS: On March 15, 2008, the lifeless body of Maria Fe Valencia was found in her rented
room at Nice Place Compound, Bgy. Nancayasan, Urdaneta City, Pangasinan. The
victim had suffered several stab wounds, and some of her personal belongings were
missing. The investigation revealed a broken knife with blood stains, uprooted hair
strands of the victim, other hair strands of unknown origin, and blood stains on the
walls and floor.

During the follow-up investigation, the outgoing security guard of the compound,
who was seen by a witness on the morning of March 15, 2008, was identified as the
accused-appellant. The witness observed that the accused-appellant's right arm
was covered, and he requested help in packing his and his pregnant wife's clothes
as they were leaving the city. The accused-appellant was not found during the initial
investigations, and his rented room was later discovered to be abandoned. He was
eventually arrested in Aklan.

In an interview with a field reporter, the accused-appellant voluntarily admitted

that he was in the victim's apartment in the early dawn of March 15, 2008,
attempting to borrow money. He confessed to taking money from the victim's bag
but claimed not to remember what happened next. Additionally, the deceased's car,
a black Mitsubishi Lancer, was surrendered by the accused-appellant's brother,
who suspected its connection to the crime.

The accused-appellant vehemently denied the accusation, claiming that he and his
wife left for Cubao, Quezon City, on the morning of March 15, 2008, and denied
visiting his brother in Laguna. He stated that his confession to the reporter was
prompted by fear.

Both the RTC and the CA found the accused-appellant guilty.

ISSUE: Whether or not the CA erred in admitting as evidence the accused-appellant’s extra-
judicial confession.

HELD: No. The Court found no merit in the appeal and upheld the findings and conclusions
of the lower courts, stating that the degree of proof required in criminal cases had
been met. The Court agreed with the admissibility of the extra-judicial confession
given by the accused-appellant during the interview conducted by the field
reporter, rejecting the assertion that the confession was involuntarily given under
extreme fear. The Court emphasized that the confession was not covered by the
constitutional provisions concerning custodial investigations and that the accused-
appellant's confession was replete with details describing the manner in which the
crime was committed.

Furthermore, the Court highlighted that the accused-appellant's confession was

corroborated by other evidence and that his culpability was proven through
circumstantial evidence. The Court emphasized that direct evidence is not the only
matrix from which a trial court may draw its conclusion and finding of guilt, and
that resort to circumstantial evidence is imperative in many cases. The Court
concluded that the circumstances and the extra-judicial confession of the accused
formed an unbroken chain leading to the fair and reasonable conclusion that the
accused-appellant perpetrated the crime.
 MANGANEY V. SANDIGANBAYAN
G.R. No. 147773-74, 18 February 2008

FACTS: The Municipality of Paracelis, Mountain Province awarded a road widening and
partial relocation project to private contractor Leon Acapen. The project was
allegedly completed on December 8, 1986, and certificates of inspection and
acceptance were prepared and signed by various individuals, attesting to the
completion of the project. However, a complaint was later filed regarding
anomalies in the construction, leading to an investigation by the Commission on
Audit (COA).

The COA's inspection revealed discrepancies in the actual accomplishment of the

excavation work compared to the reported completion. As a result, provincial
officers and the project contractor were charged before the Sandiganbayan for
defrauding the government. The accused were later acquitted, and an amended
information for estafa through falsification of public documents was filed against
Paracelis Mayor Matthew Wandag, Municipal Revenue Clerk Forayo, Municipal
Planning and Development Coordinator Wanason, and Construction and
Maintenance Foreman Mangangey.

In its decision, the Sandiganbayan found that the signatories of the Certificate of
Inspection and Acceptance falsified a public document by attesting that the project
was 100% completed, despite evidence to the contrary. The Sandiganbayan also
found that the petitioners conspired to defraud the government. The petitioners'
motion for reconsideration was denied, leading to the filing of a petition for review.

ISSUE: Whether or not Leon is guilty.

HELD: No. The Sandiganbayan acquitted Leon, the purported contractor of the project, on
the grounds of reasonable doubt, noting that he admitted to not being the real
contractor and that he did not do any work on the road. Leon reported being
threatened and coerced by Wandag, who used him as a dummy to receive payment
for the unfinished road. The petitioners contested the Sandiganbayan's findings,
arguing that the circumstances relied upon were insufficient to convict them of
estafa through falsification of public documents. They claimed that the evidence
presented did not establish their guilt beyond reasonable doubt.

The Sandiganbayan's reliance on circumstantial evidence, including erroneous

testimonies and the absence of corroboration, was contested by the petitioners.
They argued that the circumstances were insufficient to prove their guilt and that
the prosecution failed to establish their knowledge of Wandag's criminal intent to
defraud the government. The petitioners insisted that the evidence did not
overcome their constitutional and legal right to be presumed innocent.
 PEOPLE V. PUGAY
G.R. No. L-74324, 17 November 1988

FACTS: On the evening of May 19, 1982, during a town fiesta fair in Rosario, Cavite, the
accused Pugay and Samson, along with several companions, were involved in a
tragic incident. The deceased, Miranda, who was a friend of Pugay, was subjected
to cruel treatment by the group. They made him dance by tickling him with a piece
of wood and then, to everyone's horror, Pugay poured gasoline on Miranda and
Samson set him on fire, turning him into a human torch.

The ferris wheel operator and onlookers tried to extinguish the flames, and the
police arrived at the scene. Witness accounts and the actions of the accused led to
their identification as the perpetrators of the heinous act. Miranda was rushed to
the hospital for treatment, and the police took written statements from witnesses,
including Gabion and the two accused. While Gabion was released, the accused
remained in custody.

The accused initially admitted to their involvement in the crime in their written
statements to the police, but later repudiated these statements, claiming they were
extracted by force. They also attempted to shift the blame onto Gabion. The court,
however, found Gabion's testimony to be straightforward, positive, and convincing,
and it was not solely based on the written statements of the accused. The court also
addressed the non-presentation of other eyewitnesses, stating that their
testimonies would have been merely corroborative and their non-presentation did
not give rise to the presumption of adverse evidence. The accused also attacked
Gabion's credibility, but the court found no reason for him to testify falsely against
them.

ISSUE: Whether or not the accused are guilty of the crime charged.

HELD: No. The respective criminal responsibility of Pugay and Samson arising from
different acts is individual and not collective. Pugay is only guilty of homicide
through reckless imprudence for he failed to exercise the necessary diligence to
avoid every undesirable consequence arising from their act of fun-making with the
deceased. Without sufficient evidence of the qualifying circumstances, Samson is
only guilty of homicide because he had no reason or intent to kill the deceased
before the incident. Indeed, he knew that what Pugay poured was gasoline because
of the stingy smell that pervaded. What he intended was only to burn the clothes of
the deceased, but that does not relieve him of criminal responsibility. Each was
guilty only of a culpable felony.
 PEOPLE V. MANUEL
G.R. No. 93926-28, 28 July 1994

FACTS: Lucila Manuel, a receptionist at the Hot City Club and Restaurant, met Jesus
Tolentino, Jr. in November 1984 and became his lover. In February 1985, Segundo
Manuel, Lucila's first cousin, also became her lover while she continued her
relationship with Tolentino. On the evening of March 20, 1985, there were
conflicting versions of events. According to prosecution witness Teresa Manuel,
Lucila left with Segundo Manuel, Santos, and Tolentino, but returned alone with
Tolentino's bag. However, Lucila denied arranging to meet Tolentino that evening
and claimed that Segundo arrived and informed her that he had killed Santos and
Tolentino in self-defense. Subsequently, Lucila and Teresa left their residence due
to fear of police arrival. Segundo admitted to killing Santos and Tolentino but
claimed self-defense. He initially exonerated Lucila and mentioned that after the
incident, they went to different locations before being arrested by the police.

Segundo Manuel retracted his previous testimony and asserted that on the evening
of March 20, 1985, he chanced upon Lucila and Tolentino conversing. He then
described a series of events, including a confrontation and a subsequent altercation
that led to the fatal shooting of Santos and Tolentino. In her appeal, Lucila
challenges the trial court's reliance on the testimony of Teresa Manuel, who she
claims is biased, and disputes the finding of conspiracy and the qualifying
circumstance of evident premeditation. However, the court emphasized that the
trial court's findings are entitled to the highest degree of respect and will not
ordinarily be disturbed by an appellate tribunal without clear evidence of
misapplication or misunderstanding of facts. Additionally, the court noted that
appellant's bare denials cannot prevail over positive testimony, and there is no
evidence to indicate any ulterior motive on the part of Teresa that would have
urged her to wrongly implicate Lucila.

ISSUE: Whether or not the accused are guilty of the crime charged.

HELD: Yes. The appellant's bare denials cannot prevail over positive testimony, as such
denials constitute self-serving negative evidence that generally cannot be accorded
greater evidentiary weight than the declarations of witnesses testifying on
affirmative matters. The presence of prosecution witness Teresa Manuel with the
victim's sister after the commission of the crime does not render her testimony
valueless, and there is no indication of any ulterior motive on her part to wrongly
implicate the appellant. Additionally, the Court does not agree with the lower
court's conclusions regarding the existence of conspiracy, emphasizing that the
elements of conspiracy must be proven beyond reasonable doubt and that the
evidence must reasonably be strong enough to show a community of criminal
design. The Court also notes that while Lucila's presence may have encouraged
Segundo to kill Tolentino, her direct participation in the crime is not sufficiently
shown.