People of the Philippines vs.

Raymund Camarse Y Gimotea

G.R. No. 258187
Parties:
Accused: Raymund
Victim : Regine

Crime Scene:
Garage Room No. 30, Country Lodge Motel

Evidences:
Weapon : 13 cm. Knife
Vehicle : Mitsubishi Super Saloon Car

Issue : Circumstantial Evidence

 • Circumstantial evidence that merely
arouses suspicions is not sufficient to
convict. X x x. On the other hand,
circumstantial evidence, when sufficient,
may validly sustain a conviction.
• The Rules of Court allows resort to circumstantial
evidence provided the following conditions are
satisfied, to wit:
• (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 Court explained that a judgment of conviction

based on circumstantial evidence can be upheld only
if the circumstances proved constitute an unbroken
chain which leads to one fair and reasonable
conclusion which points to the accused, to the
exclusion of all others, as the guilty person.
Art 248 : Murder

• A conviction for murder requires the confluence

of the following elements, to wit:
• (1) a person was killed;
• (2) the accused killed the victim;
• (3) the killing was attended by any of the
qualifying circumstances mentioned in Article
248 of the RPC; and
• ( 4) that the killing is not parricide or infanticide.
 In this case, the prosecution established
these circumstantial pieces of evidence (Art.
248), thus:
• First, Raymund and Regine checked in at the Garage Room No. 30 of
Country Lodge Motel on July 19, 2011 at 8:51 a.m. No one else entered the
room.

• Second, the room attendant observed that black smoke was coming out of
the room at around 2: 15 p.m. Raymund came out of the room and
informed the room attendant that Regine was still inside.

• Third, Raymund fled despite the attempts of the room attendant to prevent
him from fleeing.

• Fourth, the room attendant entered the room and saw Regine 's body lying
face down.

• Fifth, the barangay officials and room boys ran after Raymund and called
the police.

• Sixth, the police an-ived and recovered a 13-centimeter kitchen knife at the
backseat of Raymund's vehicle.

• Seventh, the post-mortem examination revealed that Regine died due to

severe multiple traumatic injuries of the head with multiple stab wounds in
 Destructive Arson under RA
7659
• The elements of the offense are as follows:
• (1) a fire was set intentionally; and

• (2) the accused was identified as the

person who caused it.
 Here, the prosecution established these
circumstantial evidence sufficient to convict the
accused, viz. :
• First, Raymund and Regine checked in at the Garage Room No. 30 of Country
Lodge Motel on July 19, 2011 at 8:51 a.m. No one else entered the room.

• Second, the room attendant observed that black smoke was coming out of the
room at around 2: 15 p.m. Raymund came out of the room and informed the
room attendant that Regine was still inside.

• Third, Raymund fled despite the attempts of the room attendant to prevent
him from fleeing

• Fourth, the Arson Investigation Unit of the Bureau of Fire Protection (BFP)
examined the motel room and observed that highly combustible materials
such as crumpled papers, bedsheets, clothing, sandals, and wooden chairs
were piled on top of Regine's body. The bed also emitted the strong smell of
kerosene.

• Fifth, the BFP operatives remarked that the use of highly flammable materials
indicates that the fire was intentionally set.

• Sixth, the BFP confirmed that the debris and samples taken from the crime
scene were positive for kerosene.

• Seventh, the motel room is among the structures enumerated in Article 320 of
the RPC and that Raymund started the fire to conceal or destroy evidence of
 Rulie Compayan Camillo vs. People of the
Philippines G.R. No. 260353 (Self Defense or
Not?)

• Parties:
Accused-Appellant : Rulie
Victim/Deceased : Noel
• Criminal Liability : Homicide
• Crime Scene: Olingan, Dipolog City

Summary of Facts:
• 1. Rulie was working and carrying sack of rice
• 2. Noel was drunk and suddenly boxed Rulie
• 3. Rulie continued working but Noel boxed him again.
• 4. Rulie put down the sack of rice and punched Noel’s
nose and jaw.
• 5. Noel fell down hitting the concrete pavement
leading to his death
Was there a Self
Defense?
 SELF DEFENSE

• Self-defense requires the following:

• (1) unlawful aggression on the part of the victim;

• (2) reasonable necessity of the means employed
to prevent or repel such aggression; and
• 3) lack of sufficient provocation on the pai1 of
the person resorting to self-defense.
• We disagree with the reasoning of the trial court and
the CA. They failed to recognize the presence of
unlawful aggression from the perspective or vantage
point of Rulie.

• Noel was drunk and unruly. His intoxication and

physical violence morphed into a real, imminent, and
actual danger. Noel, at the flashpoint of the incident,
was not only inebriated with alcohol, but he was also
exuding and prevailed by-a reckless and taunting
temperament. The danger that his deportment
lurked is not hard to imagine. In many cases of
irresponsible alcohol intake, the drunk person either
has caused injury or death to somebody, or the
drunk person dies or becomes injured because of
running amok. Violence brought about by
intoxication is not uncommon. The survival instinct
of one who was physically assaulted and persistently
targeted by a drunk person will naturally resort to a
swift, successive, and unfathomed fight or flight
response.
• Yet it is arbitrary to expect restraint from Rulie. He was
physically and persistently assaulted by a wild, drunk
Noel. At the time he was attacked by Noel, Rulie was
exerting too much physical effort in carrying a heavy
sack of rice. Unlawful aggression manifests in various
forms. It cannot be pigeonholed to scenarios where there
are dangerous weapons involved. Persistent, reckless, and
taunting fist blows can equally cause grave danger and
harm. To a discriminating mind, the imminence of
unlawful aggression is obscured by the instinct of self-
preservation. This is particularly true in the case of Rulie
who, while doing a strenuous job, was suddenly boxed by
a drunk person for no apparent reason.

• We disagree that unlawful aggression had ceased when

Rulie had put down the sack of rice. All the eyewitnesses
attested that Noel did not stop attacking Rulie after the
latter put down the first and second sacks of rice. Noel
was still in a fighting stance until he met the wrath of
Rulie's defense. In his right, Rulie had to enable himself
to repel the unlawful aggression with reasonable force.
Otherwise, he might lose his balance and incur fatal
injuries, apart from the ones caused by Noel's