G.R. No. 118131 -32 May 5, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EMILIO RABUTIN, accused-appellant.

FACTS

Accused-appellant Emilio Rabutin was convicted by the Regional Trial Court for three counts of Murder and one count of Frustrated Murder. The charges stemmed from the shooting deaths of Leonardo, Wilma, and Warren delas Alas, and the wounding of Glendy delas Alas on the evening of July 18, 1988, in Zamboanga del Sur. The prosecution’s case relied primarily on the eyewitness account of Rodrigo Gumilos, who testified that he saw Rabutin firing an M16 armalite rifle at the victims. The prosecution also presented the testimonies of Celso and Pedro Suco, who were with Rabutin that evening. They claimed they went to the victims’ house to confront Leonardo but asserted that Rabutin was the sole gunman.
Rabutin, in his defense, denied the allegations and pointed to Celso Suco as the actual perpetrator. He argued that the prosecution witnesses’ testimonies were inconsistent and incredible. The trial court, however, found the eyewitness identification credible and noted a chain of circumstantial evidence supporting Rabutin’s guilt, including his presence at the scene, his flight immediately after the shootings, and his failure to report the incident to authorities. Despite Rabutin’s defense, only he was charged, while the Suco brothers were utilized as prosecution witnesses.

ISSUE

The core issue is whether the trial court erred in convicting accused-appellant Rabutin based on the testimonial and circumstantial evidence presented by the prosecution.

RULING

The Supreme Court affirmed the conviction. The Court held that the positive identification by eyewitness Rodrigo Gumilos was credible and sufficient to establish Rabutin’s guilt beyond reasonable doubt. Gumilos provided a clear and consistent account of seeing Rabutin fire the weapon. The Court found no compelling reason to disregard this testimony, as alleged inconsistencies were minor and did not pertain to the core fact of witnessing the shooting.
Regarding the circumstantial evidence, the Court applied the standard that such evidence is sufficient for conviction if: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all circumstances produces a conviction beyond reasonable doubt. The circumstances—Rabutin’s presence at the crime scene with the Suco brothers, the immediate flight of all three after the gunshots, their return to the scene the next day, and Rabutin’s failure to report the crime—formed an unbroken chain leading to the reasonable and singular conclusion of his guilt, inconsistent with any hypothesis of innocence.
The Court also ruled that the lack of a clear motive on Rabutin’s part was immaterial. Motive is not an element of the crime of murder. When the accused is positively identified as the perpetrator, as in this case, the absence of motive does not weaken the prosecution’s case. Furthermore, Rabutin’s conduct after the crime, particularly his flight and silence, betrayed a guilty conscience. The Court thus upheld the trial court’s judgment and directed the Department of Justice to investigate the Suco brothers for possible criminal liability.