G.R. No. 210760 ; January 26, 2015
KYLE ANTHONY ZABALA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioner Kyle Anthony Zabala was charged with theft for allegedly stealing an envelope containing ₱68,000 from Randolph Alas on June 18, 2007, in San Jose del Monte City, Bulacan. The prosecution presented Alas, the complainant, and Marlyn Piñon, Zabala’s alleged girlfriend. Alas testified that he discovered the money missing from his closet upon returning home from work. He stated that Zabala, a neighbor and mechanic he often invited for drinks, had access to his bedroom when fetching cash for vehicle repairs. Piñon testified that in the early morning of June 18, 2007, she saw Zabala climb a fence and tree to enter Alas’s house, return with a bulge in his pocket (later revealed as money), and later buy two mobile phones in Greenhills. The defense presented Zabala and Muriel John Ganas, who testified that Zabala was driving his jeepney with Ganas as conductor during the alleged incident and did not go to Alas’s house or meet Piñon. The Regional Trial Court convicted Zabala of theft, sentencing him under the Indeterminate Sentence Law. The Court of Appeals affirmed the conviction but modified the penalty. Zabala appealed to the Supreme Court, arguing insufficient evidence.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove Zabala’s guilt beyond reasonable doubt for the crime of theft.

RULING

The Supreme Court REVERSED the Court of Appeals and ACQUITTED Zabala. The Court held that the prosecution failed to prove guilt beyond reasonable doubt through circumstantial evidence. For circumstantial evidence to suffice under Rule 133, Section 4 of the Rules of Court, there must be: (1) more than one circumstance; (2) proven facts from which inferences are derived; and (3) a combination of circumstances producing conviction beyond reasonable doubt. Crucially, such evidence must form an unbroken chain leading to a fair and reasonable conclusion pointing to the accused as the guilty person, to the exclusion of all others. Here, the prosecution did not establish that it was impossible for someone else to have committed the theft. Alas admitted other residents (his parents, aunt, and son) were in the house, but they were not presented to account for their whereabouts. The evidence did not exclude the possibility that another person took the money. Thus, the presumption of innocence prevails, and Zabala is acquitted due to reasonable doubt.