G.R. No. 104497 January 18, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEX RAMOS alias “BULKO” (at large), accused, ANGEL FERNANDEZ, RODOLFO TULAGAN AND MARCO FERNANDEZ, accused-appellants.

FACTS

On the evening of October 26, 1987, a robbery with homicide occurred at the residence of Aida Sison in Rizal, Laguna. The victims, Aida Sison and her maid Avelina Hernandez, were found dead inside their ransacked house, with jewelry and cash missing. There were no eyewitnesses to the crime. Police, responding to a report, surrounded the house and later found appellants Angel Fernandez and Marco Fernandez crawling on the ground nearby. Angel was apprehended holding a blood-stained dagger. The following morning, appellant Rodolfo Tulagan was arrested not far from the scene, with a knife in his possession.
The defense presented a different narrative. Appellants claimed they were in the area because their acquaintance, Alex Ramos, invited them to buy lanzones. They spent time at the victim’s store before Alex led them to a nearby school compound, where he left them. They testified they heard a woman scream for help, implicating Alex Ramos, and fled upon hearing gunshots, which led to their apprehension.

ISSUE

Whether the guilt of the appellants for the crime of Robbery with Homicide has been proven beyond reasonable doubt based on circumstantial evidence.

RULING

Yes. The Supreme Court affirmed the conviction, ruling that the totality of the circumstantial evidence sufficiently established appellants’ guilt. The legal logic rests on the requirements for circumstantial evidence under the Rules of Court: (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 produces a conviction beyond reasonable doubt. The Court found these conditions satisfied.
The circumstances, taken together, form an unbroken chain leading to the reasonable conclusion that appellants committed the crime. These include: their presence at the crime scene with their co-accused Alex Ramos earlier that day; their apprehension within the immediate vicinity shortly after the crime; their possession of bladed weapons, with Angel’s dagger stained with blood; their attempt to flee and hide, indicating consciousness of guilt; and the medical finding that the victims’ wounds were consistent with the weapons found in their possession. Their denial and alibi were inherently weak and could not prevail over the positive circumstantial evidence. The Court emphasized that direct evidence is not indispensable for conviction, and circumstantial evidence, when credible and conclusive, is sufficient to support a finding of guilt.