G.R. No. 134606 ; November 29, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FREDDIE ABILLAR, RAFAEL MEDINA and MARLON BAUTISTA (at large), accused-appellants.

FACTS

Noel Ancheta was last seen alive on the night of March 17, 1996, in the company of his first cousins, accused-appellants Freddie Abillar and Rafael Medina, and Marlon Bautista. Witnesses Joel Samson and Robert Lozano testified that the three accused blocked their path, with Abillar holding a knife and a stone, and Medina holding a stone. Abillar placed an arm around Ancheta, stating they would just talk at a nearby basketball court. The witnesses saw the group, with Medina pushing Ancheta, proceed toward the court. When Ancheta failed to return, a search commenced. The following days, both Medina and Abillar, when separately asked about Ancheta’s whereabouts, denied any knowledge.
Ancheta’s decomposing body was discovered on March 24, 1996, in a cornfield. An autopsy revealed a stab wound on the chest and a fracture at the back of the head, injuries consistent with the knife and stones the accused were seen carrying. After the discovery, police investigation found that all three accused had left their homes and gone into hiding. Rafael Medina was arrested on April 17, 1996, and Freddie Abillar on June 30, 1996, in a different province. Marlon Bautista remained at large. The accused interposed alibi, claiming they were elsewhere on the night in question.

ISSUE

Whether the conviction of the accused-appellants for the killing of Noel Ancheta based on circumstantial evidence is valid.

RULING

Yes, the conviction is valid, but modified from Murder to Homicide. The Supreme Court affirmed that circumstantial evidence can sustain a conviction if it meets the requisites under the Rules of Court: there is more than one circumstance; the facts from which inferences are derived are proven; and the combination of all circumstances produces a conviction of guilt beyond reasonable doubt. The Court found an unbroken chain of circumstances leading to one rational conclusion: the guilt of the accused. These circumstances include: the accused were the last persons seen with the victim; they were armed with a knife and stones matching the victim’s injuries; they gave evasive answers when later inquired about the victim; they fled and hid after the body was discovered; and the victim’s body was found in a location within the area they were last seen heading. The combination of these facts is consistent only with the hypothesis of guilt and inconsistent with innocence. However, the prosecution failed to prove any qualifying circumstance to elevate the crime to Murder. Thus, accused-appellants Freddie Abillar and Rafael Medina are guilty of Homicide. The case against Marlon Bautista was archived pending his arrest.