GR 134402; (February, 2001) (Digest)
G.R. No. 134402 February 5, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NARCISO BAYANG y LEYPOS, DANILO DOMDOM y CONGOLO, and PEDRO PENZA y CANTILLA, accused-appellants.
FACTS
On August 15, 1995, prosecution witness Alexander Rodelas observed accused-appellants alight from an Angeleah taxicab along Osias Street in Makati. Noticing blood on the front seat and the missing taximeter and radio, he reported the incident. Later, Alexander confronted the appellants on P. Burgos Street, prompting them to curse him. As Alexander shouted for help, police officer Marvin Fajilan responded. A search of the appellants yielded a blaster stereo and taximeter from Bayang, a .38 caliber revolver from Penza, and the taxicab keys from Domdom.
That same evening, a body identified as Edilberto Espiritu, the driver of the taxicab bearing plate number TSJ-568, was found dead from a gunshot wound along Sauyo Road, Novaliches, Quezon City. Accused-appellants were charged with robbery with homicide. The Regional Trial Court convicted them, sentencing each to reclusion perpetua and ordering them to pay damages. Narciso Bayang later withdrew his appeal, leaving Danilo Domdom and Pedro Penza as the appellants contesting the sufficiency of the circumstantial evidence.
ISSUE
Whether the circumstantial evidence presented is sufficient to prove the guilt of accused-appellants Danilo Domdom and Pedro Penza for the crime of robbery with homicide beyond reasonable doubt.
RULING
Yes, the conviction is affirmed. The Supreme Court held that while no eyewitness directly saw the commission of the crime, the totality of the circumstantial evidence meets the legal standard for conviction. Under Rule 133, Section 4 of the Revised Rules on Evidence, circumstantial 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 the circumstances produces a conviction beyond reasonable doubt.
The chain of circumstances is complete and points to the appellants’ guilt. They were seen alighting from the victim’s taxicab, which showed signs of a violent struggle. They were found in possession of items belonging to the taxicab immediately after the incident. The victim, found dead shortly thereafter, was the driver of that same vehicle. Their flight and hostile reaction upon being confronted further indicated consciousness of guilt. The Court found no break in this chain of evidence, which excludes any reasonable hypothesis of innocence. The appealed decision was affirmed with modification, deleting the award for funeral expenses due to lack of supporting receipts and adjusting the damages awarded.