considered as analogous to an attempt to compromise, which in turn can be received as an implied

admission ofguilt under Section 27, Rule 130

The rule is that no evidence shall be allowed during trial if it was not identified and pre-marked
during trial. This provision, however, allows for an exception: when allowed by the court for good
cause shown. There is no hard and fast rule to determine what may constitute "good cause," though
this Court has previously defined it as any substantial reason "that affords a legal excuse."65

G.R. No. 172695 June 29, 2007

PEOPLE OF THE PHILIPPINES, Appellee,

vs.
ISAIAS CASTILLO y COMPLETO, Appellant.

Direct evidence of the commission of the offense is not the only matrix wherefrom a trial court may
draw its conclusions and finding of guilt. Conviction can be had on the basis of circumstantial
evidence provided that: (1) there is more than one circumstance; (2) the facts from which the
inferences are derived are proven; and (3) the combination of all the circumstances is such as to
produce a conviction beyond reasonable doubt. While no general rule can be laid down as to the
quantity of circumstantial evidence which will suffice in a given case, all the circumstances proved
must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at
the same time inconsistent with the hypothesis that he is innocent, and with every other rational
hypothesis except that of guilt. The circumstances proved should constitute an unbroken chain
which leads to only one fair and reasonable conclusion that the accused, to the exclusion of all
others, is the guilty person.8 Proof beyond reasonable doubt does not mean the degree of proof
excluding the possibility of error and producing absolute certainty. Only moral certainty or "that
degree of proof which produces conviction in an unprejudiced mind" is required.9

SAME CASE TITLE AS ABOVE

It is well-established that the flight of an accused is competent evidence to indicate his guilt, and
flight, when unexplained, as in this case, is a circumstance from which an inference of guilt may be
drawn.

FOR REVISION

It might be true that the accused was one of those who reported the incident to
angelo rushed the victim to the hospital and while on the way, he sounded remorseful. But
Guillermo Antiporta further testified that while the victim was being attended to by the medical
personnel of said hospital, the accused stayed outside the hospital premises, then he disappeared.
He was later on apprehended by police authorities while hiding inside the comfort room of a
premises in an adjoining barangay. The accused’s omission to surrender himself to the authorities is
a clear indication of guilt

Also notable is accused-appellant’s behavior immediately after the incident. He disappeared and did
not enter the clinic where Consortia was rushed for treatment. And when Consortia’s sister later
sought police assistance in searching for accused-appellant, the latter was found by the police hiding
inside a toilet at a nearby barangay

In the instant case, the following circumstances satisfactorily established appellant’s intent to kill his
wife

WORDS TO USE

Stripped of unnecessary verbiage

appraisal of events

G.R. No. 115067 December 19, 1995

PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
JOSE GOMEZ, RODOLFO CORTES, JEFFREY YAP, MARIO TEVES, GLEN MARQUEZ, SAMUEL
PASTOR, CENON LENTIC, JR. and JOEL CATAQUE, accused.

MARIO TEVES Y ORTEGA, accused-appellant.

The flight of an accused is competent evidence to indicate his guilt and flight when unexplained is a
circumstance from which an inference of guilt may be drawn. 39 Verily, the wicked flee even when no man
pursueth but the righteous are as bold as a lion.

G.R. No. 204544

MARLON BACERRA y TABONES, Petitioner

vs.
PEOPLE OF THE PHILIPPINES, Responden

Direct evidence and circumstantial evidence are classifications of evidence with legal consequences.
The difference between direct evidence and circumstantial evidence involves the relationship of the
fact inferred to the facts that constitute the offense. Their difference does not relate to the probative
value of the evidence.

Direct evidence proves a challenged fact without drawing any inference.70 Circumstantial evidence,
on the other hand, "indirectly proves a fact in issue, such that the factfinder must draw an inference
or reason from circumstantial evidence."71

The probative value of direct evidence is generally neither greater than nor superior to circumstantial
evidence.72The Rules of Court do not distinguish between "direct evidence of fact and evidence of
circumstances from which the existence of a fact may be inferred."73 The same quantum of evidence
is still required. Courts must be convinced that the accused is guilty beyond reasonable doubt.74

A number of circumstantial evidence may be so credible to establish a fact from which it may be
inferred, beyond reasonable doubt, that the elements of a crime exist and that the accused is its
perpetrator.75 There is no requirement in our jurisdiction that only direct evidence may convict.76 After
all, evidence is always a matter of reasonable inference from any fact that may be proven by the
prosecution provided the inference is logical and beyond reasonable doubt.

Rule 113, Section 4 of the Rules on Evidence provides three (3) requisites that should be
established to sustain a conviction based on circumstantial evidence:

Section 4. Circumstantial evidence, when sufficient. - 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.77

The commission of a crime, the identity of the perpetrator,78 and the finding of guilt may all be
established by circumstantial evidence.79 The circumstances must be considered as a whole and
should create an unbroken chain leading to the conclusion that the accused authored the crime.80

The determination of whether circumstantial evidence is sufficient to support a finding of guilt is a

qualitative test not a quantitative one.81 The proven circumstances must be "consistent with each
other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent
with the hypothesis that he is innocent, and with every other rational hypothesis except that of
guilt."82

G.R. No. 206236 July 15, 2013

GILFREDO BACOLOD, a.k.a. GILARDO BACOLOD, Accused-Petitioner,

vs.
PEOPLE OF THE PHILIPPINES, Pla
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.

In Reyes v. Pearlbank Securities, Inc.,22 this Court held: G.R. No. 171435, July 30, 2008, 560 SCRA
518.

Probable cause, for the purpose of filing a criminal information, has been defined as such facts as
are sufficient to engender a well-founded belief that a crime has been committed and that
respondent is probably guilty thereof. The term does not mean "actual and positive cause" nor does
it import absolute certainty. It is merely based on opinion and reasonable belief. Probable cause
does not require an inquiry into whether there is sufficient evidence to procure a conviction. It is
enough that it is believed that the act or omission complained of constitutes the offense charged.

A finding of probable cause needs only to rest on evidence showing that, more likely than not, a
crime has been committed by the suspects. It need not be based on clear and convincing evidence
of guilt, not on evidence establishing guilt beyond reasonable doubt, and definitely not on evidence
establishing absolute certainty of guilt. In determining probable cause, the average man weighs facts
and circumstances without resorting to the calibrations of the rules of evidence of which he has no
technical knowledge. He relies on common sense. What is determined is whether there is sufficient
ground to engender a well-founded belief that a crime has been committed, and that the accused is
probably guilty thereof and should be held for trial. It does not require an inquiry as to whether there
is sufficient evidence to secure a conviction.23

G.R. No. 189176 March 19, 2014

BARRY LANIER and PERLITA LANIER, Petitioners,

vs.
PEOPLE OF THE PHILIPPINES, Respondents.

As a requisite to the filing of a criminal complaint, probable cause pertains to facts and
circumstances sufficient to incite a well-founded belief that a crime has been committed and the
accused is probably guilty thereof.

Only such facts sufficient to support a prima facie case against the respondent are required, not
absolute certainty. Probable cause implies mere probability of guilt, i.e., a finding based on more
than bare suspicion but less than evidence that would justify a conviction. What is determined is
whether there is sufficient ground to engender a well-founded belief that a crime has been
committed, and that the accused is probably guilty thereof and should be held for trial.15

reyes

A finding of probable cause needs only to rest on evidence showing that, more likely than not, a
crime has been committed by the suspects. It need not be based on clear and convincing evidence
of guilt, not on evidence establishing guilt beyond reasonable doubt, and definitely not on evidence
establishing absolute certainty of guilt. In determining probable cause, the average man weighs facts
and circumstances without resorting to the calibrations of the rules of evidence of which he has no
technical knowledge. He relies on common sense. What is determined is whether there is sufficient
ground to engender a well-founded belief that a crime has been committed, and that the accused is
probably guilty thereof and should be held for trial. It does not require an inquiry as to whether there
is sufficient evidence to secure a conviction.20