G.R. No. 133226 ; March 16, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LOCSIN FABON @ “Loklok,” accused-appellant.

FACTS

On April 23, 1995, in Hilongos, Leyte, Bonifacia Lasquite was found dead in her home. The prosecution’s case was built primarily on circumstantial evidence. The key witness was Benjamin Milano, the nine-year-old nephew of the accused-appellant, Locsin Fabon. Milano testified that early that morning, while fetching water near the victim’s house, he saw Fabon emerging from the victim’s fence. Fabon’s forehead, shirt, and hair were stained with blood, he was carrying a plastic bag, and had a bolo tucked in his pants. Fabon then hurriedly left the scene. Later that day, upon learning of Lasquite’s death, Milano reported his sighting to the victim’s son.
Further evidence was provided by Mario Vinculado, who testified that in August 1995, he and a police officer located Fabon in Butuan City. While in custody there, Fabon admitted to Vinculado that he had a companion during the assault and that he stabbed the victim twice. The autopsy report detailed the victim’s extensive injuries, including lacerated and stab wounds, depressed skull fractures, and hematomas, which indicated a violent death accompanied by rape and mutilation.

ISSUE

The central issue was whether the circumstantial evidence presented by the prosecution was sufficient to prove beyond reasonable doubt that Locsin Fabon committed the complex crime of robbery with homicide, accompanied by rape and intentional mutilation.

RULING

The Supreme Court affirmed the conviction and the imposition of the death penalty. The Court meticulously applied the rules on circumstantial evidence, which require 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 prosecution successfully established a complete chain of circumstances unerringly pointing to Fabon’s guilt.
These circumstances included: (1) Fabon was seen by a credible witness leaving the victim’s premises at dawn, covered in blood and carrying a bag; (2) he fled Hilongos immediately after the crime; (3) he was apprehended months later in another city; (4) he made a judicial admission to Vinculado about his involvement; and (5) the autopsy findings were consistent with a brutal robbery-homicide. The Court found no reason to doubt the testimony of the young eyewitness, whose account was straightforward and consistent. Fabon’s flight and his extrajudicial confession, though not admissible as a formal confession, further corroborated the evidence against him. The totality of these facts excluded any reasonable possibility of innocence. The crime was qualified by the attendant circumstances of rape and intentional mutilation, warranting the supreme penalty under Article 294 of the Revised Penal Code.