G.R. No. 118457 . April 8, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FIDEL LAGAO, JR., defendant-appellant.

FACTS

Accused-appellant Fidel Lagao, Jr. was charged with parricide for the death of his wife, Gloria Castro Lagao. The prosecution established a history of marital discord marked by the accused’s jealousy, physical violence, and threats against the victim. On October 30, 1989, Gloria was last seen alive boarding the passenger jeepney driven by the accused. She never returned home. Her decomposing body was discovered days later in a grassy area, bearing multiple stab wounds. The accused, when confronted by the victim’s brother, denied knowledge of her whereabouts. Upon his arrest, he was found to have several fresh abrasions on his body.

ISSUE

The core issue is whether the guilt of the accused for the crime of parricide has been proven beyond reasonable doubt.

RULING

Yes. The Supreme Court affirmed the conviction. The decision rested on the confluence of circumstantial evidence sufficient to establish moral certainty of the accused’s guilt. The chain of circumstances was unbroken: the accused had motive, evidenced by a documented history of violent quarrels and threats; he had the exclusive opportunity, being the last person seen with the victim when she boarded his jeepney; and the victim’s body was found along his jeepney route. His unexplained fresh injuries, inconsistent with his claim of repairing his vehicle, were highly indicative of a struggle. His implausible and shifting explanations for these injuries further damaged his credibility. The Court emphasized that direct evidence is not indispensable for conviction; circumstantial evidence, when it constitutes an unbroken chain leading to a fair and reasonable conclusion of guilt, is sufficient. All circumstances, taken together, point to the accused as the perpetrator to the exclusion of all others, thereby meeting the required standard of proof beyond reasonable doubt.