LEGAL NOTE 0031: PRIMER ON CIRCUMSTANTIAL EVIDENCE

SOURCE:  BENJAMIN JESALVA VS. PEOPLE OF THE PHILIPPINES (G.R. NO. 187725,19 JANUARY 2011, NACHURA, J.) SUBJECTS: HOMICIDE; CIRCUMSTANTIAL EVIDENCE; CUSTODIAN INVESTIGATION. (BRIEF TITLE: JESALVA VS. PEOPLE)

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SUFFICIENCY OF CIRCUMSTANTIAL EVIDENCE AS APPLIED TO ABOVE CASE.

Be that as it may, even without these statements, petitioner could still be convicted of the crime of Homicide. The prosecution established his complicity in the crime through circumstantial evidence, which were credible and sufficient, and which led to the inescapable conclusion that petitioner committed the said crime. Indeed, when considered in their totality, the circumstances point to petitioner as the culprit.

IS DIRECT EVIDENCE THE ONLY SIFFICIENT BASIS FOR CONVICTION.

NO.

Direct evidence of the commission of the crime charged is not the only matrix wherefrom a court may draw its conclusions and findings of guilt.

 

HOW CAN A WITNESS IDENTIFY AN ACCUSED WHEN HE DID NOT SEE HIM COMMIT THE CRIME?

There are instances when, although a witness may not have actually witnessed the commission of a crime, he may still be able to positively identify a suspect or accused as the perpetrator of a crime as when, for instance, the latter is the person last seen with the victim immediately before and right after the commission of the crime. This is the type of positive identification, which forms part of circumstantial evidence. In the absence of direct evidence, the prosecution may resort to adducing circumstantial evidence to discharge its burden.

 

WHY IS CIRCUMSTANTIAL EVIDENCE ADMISSIBLE?

Crimes are usually committed in secret and under condition where concealment is highly probable. If direct evidence is insisted upon under all circumstances, the guilt of vicious felons who committed heinous crimes in secret or in secluded places will be hard, if not well-nigh impossible, to prove.

 

WHEN CAN THERE BE A VERDICT OF CONVICTION BASED ON CIRCUMSTANTIAL EVIDENCE?

Thus, there can be a verdict of conviction based on circumstantial evidence when the circumstances proved form an unbroken chain which leads to a fair and reasonable conclusion pinpointing the accused, to the exclusion of all the others, as the perpetrator of the crime.  

 

WHAT ARE THE ESSENTIAL REQUISITES IN ORDER THAT CIRCUMSTANTIAL EVIDENCE MAY BE SUFFICIENT TO CONVICT?

However, in order that circumstantial evidence may be sufficient to convict, the same must comply with these essential requisites, viz.:

(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.