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particular requirements for the former to be relied on. Jurisprudence returns to this theme again
and again:
Cases
It is a settled rule that circumstantial evidence is sufficient to support a conviction, and that direct
evidence is not always necessary. This is but a recognition of the reality that in certain instances,
due to the inherent attempt to conceal a crime, it is not always possible to obtain direct evidence.
In Bacolod v. People, this Court had the occasion to say:
The lack or absence of direct evidence does not necessarily mean that the guilt of the accused
cannot be proved by evidence other than direct evidence. Direct evidence is not the sole means
of establishing guilt beyond reasonable doubt, because circumstantial evidence, if sufficient, can
supplant the absence of direct evidence. The crime charged may also be proved by circumstantial
evidence, sometimes referred to as indirect or presumptive evidence. Circumstantial evidence
has been defined as that which goes to prove a fact or series of facts other than the facts in
issue, which, if proved, may tend by inference to establish a fact in issue.
The Rules of Court itself recognizes that circumstantial evidence is sufficient for conviction,
under certain circumstances:
(2) The facts from which the inferences are derived are proven;
(3) The combination of all the circumstances is such as to produce a conviction beyond a
reasonable doubt.
Moreover, in Lozano v. People, this Court clarified the application of the circumstantial evidence
rule:
Preliminarily, we note that the lack of direct evidence does not ipso facto bar the finding of guilt
against the appellant. As long as the prosecution establishes the appellants participation in the
crime through credible and sufficient circumstantial evidence that leads to the inescapable
conclusion that the appellant committed the imputed crime, the latter should be convicted.
According to Section 4, Rule 133 of the Rules of Court, 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.
X X X
In People v. Oliva, we upheld the conviction of the accused based on circumstantial evidence.
In Oliva, the victim was abducted from his home, was last seen alive in the custody of the
accused, and was hog-tied with coralon rope. Although no one saw the actual killing, we held
that there was sufficient circumstantial evidence to find the accused guilty beyond reasonable
doubt.
In yet another case People v. Corfin we upheld the conviction of the accused based on
evidence showing that: (1) the accused was the last person seen with the victim; (2) the accused
and the victim were seen together near a dry creek; (3) the accused was seen leaving the place
alone; and (4) the body of the victim was later found in the dry creek.
All these cases show that the Court, when presented with sufficient circumstantial evidence, will
not shirk from upholding an accuseds conviction for murder. There are more than enough
reasons to similarly act in this case where the law and the attendant facts, considered in relation
to one another, lead to the single conclusion that the appellant participated in the killing of
Resuelo, Sr.
Circumstantial evidence consists of proof of collateral facts and circumstances from which the
main fact in issue may be inferred based on reason and common experience. Under Section 4,
Rule 133 of the Revised Rules of Court, circumstantial evidence is sufficient for conviction if the
following requisites concur: (a) there is more than one circumstance; (b) the facts from which the
inferences are derived have been established; and (c) the combination of all the circumstances
unavoidably leads to a finding of guilt beyond reasonable doubt. These circumstances must be
consistent with one another, and the only rational hypothesis that can be drawn therefrom must
be the guilt of the accused.
For circumstantial evidence to be sufficient for conviction, the following conditions must be
satisfied:
(b) The facts from which the circumstances are derived are proven; and
(c) The combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.
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