G.R. No. 108733 September 16, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENANTE PAREL y TEJAMO, accused-appellant.

FACTS

On March 4, 1992, Leticia Perez was found dead by strangulation in her third-floor bedroom at her restaurant, Le Mars Food House, in Ermita, Manila. Earlier that day, her son Michael had placed P4,000 in cash into her bag, which she took to her room. The accused-appellant, Renante Parel, was the common-law husband of Leticia’s half-sister and supervisor, Estrellita. He was a former employee who frequented the premises. Witnesses placed him inside the building, moving between floors, around the time of the crime. He was seen near the stairs and comfort room in the afternoon. Later that evening, after the discovery of the body, Estrellita turned over P3,000 to the police, claiming it was part of P6,000 given to her by Parel on the day of the killing. Parel was convicted of robbery with homicide by the Regional Trial Court.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that Renante Parel committed the special complex crime of robbery with homicide.

RULING

No. The Supreme Court reversed the conviction and acquitted Renante Parel. The Court emphasized that a conviction based solely on circumstantial evidence requires that the circumstances constitute an unbroken chain leading to one fair and reasonable conclusion of guilt, to the exclusion of all others. Here, the prosecution failed to meet this stringent standard. While the evidence placed Parel at the scene, it did not directly and conclusively link him to the killing and the taking of money. His presence and movements were not inconsistent with innocent activity, given his relationship to an employee and his history at the restaurant. The alleged extrajudicial confession was not sufficiently established, and the money turned over by Estrellita lacked a definitive connection to the specific cash missing from the victim. The weakness of the defense does not relieve the prosecution of its burden to prove guilt beyond reasonable doubt. The evidence did not form a complete and convincing chain pointing exclusively to Parel’s guilt, thereby failing to overcome the constitutional presumption of innocence. The Court held that where the evidence engenders reasonable doubt, acquittal is imperative.