G.R. No. 132745 ; March 9, 2000
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMEO UGIABAN LUMANDONG, accused-appellant.

FACTS

The case involves the murder of eight-year-old Analou Eduave. Her lifeless, naked body, bearing multiple stab and hack wounds, was discovered near the Iponan River on December 1, 1995. The prosecution established that the victim was last seen asleep in her family home the previous evening. No eyewitnesses to the killing existed. The conviction of appellant Romeo Lumandong primarily rested on circumstantial evidence. This evidence included his extrajudicial confession, corroborated by the testimony of a barangay official who witnessed its execution, and his subsequent re-enactment of the crime. The prosecution also presented physical evidence, such as the victim’s clothing found in the appellant’s house and the medico-legal findings detailing the brutal nature of the wounds.
The Regional Trial Court found Lumandong guilty of murder qualified by treachery and abuse of superior strength, and sentenced him to death. The case was elevated to the Supreme Court for automatic review. The defense argued that the conviction based on circumstantial evidence was insufficient and that the extrajudicial confession was inadmissible, having been allegedly obtained without the assistance of counsel.

ISSUE

The principal issue is whether the circumstantial evidence presented by the prosecution, including the appellant’s extrajudicial confession, is sufficient to establish his guilt for the crime of murder beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court held that a conviction based on circumstantial evidence is permissible under Rule 133, Section 4 of the Rules of Court, provided that: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt. The totality of the circumstances in this case—the appellant’s extrajudicial confession, the corroborative re-enactment, the discovery of the victim’s clothing in his possession, and the medical evidence—formed an unbroken chain leading to the inescapable conclusion that he was the perpetrator.
The Court found the extrajudicial confession admissible. It was executed with the assistance of a lawyer from the Public Attorney’s Office, as attested to by a barangay official, and the appellant failed to present clear evidence of coercion or violence. The confession was further corroborated by evidence corpus delicti. The killing was correctly classified as murder, qualified by treachery, as the attack on a defenseless, sleeping child ensured the execution of the crime without risk to the assailant. However, the Court applied the privileged mitigating circumstance of minority, as the appellant was only 14 years, 8 months, and 15 days old at the time of the crime. This reduced the penalty from death to an indeterminate sentence of six (6) years of prision correccional, as minimum, to ten (10) years and one (1) day of prision mayor, as maximum. The award of civil indemnity and damages to the victim’s heirs was sustained.