GR 124871; (May, 2004) (Digest)
G.R. No. 124871; May 13, 2004
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARIFE BELLO y ROSCO @ “Joann Redillo,” et al., accused, MARIFE BELLO y ROSCO and ELADIO M. CONSUELO, JR., accused-appellants.
FACTS
On July 25, 1995, accused-appellants Marife Bello and Eladio Consuelo, Jr. checked into Room 2 of Queensland Lodge in Pasay City. Posing as “Joann Redillo,” Marife called Sunshine Moneychanger, falsely claiming she wished to convert yen to pesos in her room. The establishment dispatched messenger Rolando Andasan with P114,000.00 to the lodge. Lodge employees escorted Andasan to the room and witnessed appellants inside. Shortly after Andasan entered, appellants hastily checked out. When employees later inspected the room, they discovered Andasan’s lifeless body with 28 stab wounds. The money was missing. Appellants were apprehended, while their two other alleged cohorts remained at large.
The prosecution presented no eyewitness to the actual killing and robbery. Its case was built entirely on circumstantial evidence, detailing the sequence from appellants’ check-in using aliases, the deceptive phone call luring the victim, the victim’s entry into their room, their immediate and hurried departure coinciding with the discovery of the corpse, and their flight. Appellants denied the charges, presenting alibis and claiming they were framed.
ISSUE
Whether the guilt of accused-appellants for the crime of Robbery with Homicide was proven beyond reasonable doubt based solely on circumstantial evidence.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the rules on circumstantial evidence, which 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 prosecution successfully established an unbroken chain of events leading to the inescapable conclusion that appellants were the perpetrators.
The logical sequence was compelling: appellants secured a private room under false pretenses, orchestrated the victim’s arrival with a large sum of money, were the last persons seen with him alive, fled immediately thereafter, and the crime was discovered moments after their departure. Their coordinated actions, use of aliases, and the implausibility of their alibis reinforced the inference of conspiracy. The Court held that the totality of the circumstantial evidence excluded every reasonable hypothesis of innocence, meeting the standard of proof beyond reasonable doubt. Appellants were sentenced to reclusion perpetua and ordered to pay restitution and damages.