G.R. No. 103627 September 5, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MOISES BACAMANTE y ORDANIZA, accused-appellant.

FACTS

Accused-appellant Moises Bacamante, an employee of Chua Huat Enterprises, was charged with robbery with homicide for the killing of his employer, Chua Huat, on December 19, 1985. The prosecution’s case was built on circumstantial evidence. It was established that on the evening of the crime, smoke was seen emanating from the hardware store. The victim was found dead, with money missing, and an attempt to burn the store using flat irons placed on paint thinner cans was discovered. Bacamante was seen near the store that evening, had cut electric cords similar in length to those used in the arson attempt earlier that day, and had left work early. After the crime, he did not report for work and was later arrested in his Bohol hometown after initially fleeing from police.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant beyond reasonable doubt for the crime of robbery with homicide.

RULING

The Supreme Court ACQUITTED accused-appellant Moises Bacamante. The Court ruled that the totality of the circumstantial evidence failed to meet the required standard of proof beyond reasonable doubt. For circumstantial evidence to sustain a conviction, the combination of circumstances must be consistent with each other, consistent with the hypothesis that the accused is guilty, and inconsistent with any other rational hypothesis except that of guilt. The circumstances presented—his presence near the store, cutting of electric cords, failure to report to work, and flight upon seeing the police—did not constitute an unbroken chain leading to the inescapable conclusion of his guilt. The Court found alternative explanations for his actions: the cord-cutting could have been for a customer, his absence from work coincided with the Christmas vacation, and his flight could have been motivated by fear of reprisal from a police officer who was a close friend of the victim. Notably, the testimony of Teresita Guy, who heard the victim’s son state that another person was responsible, further weakened the prosecution’s case. The constitutional presumption of innocence and the requirement of moral certainty for conviction compelled the Court to resolve all doubts in favor of the accused.