GR 138402; (August, 2000) (Digest)
G.R. No. 138402 ; August 18, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARNOLD GONZALES alias “ANOD”, accused-appellant.
FACTS
On August 18, 1996, around 1:00 a.m., Leolito Paquelet was found dead from multiple stab wounds on a bench outside a store in Kidapawan, Cotabato, shortly after attending a benefit dance. There were no eyewitnesses to the actual stabbing. The prosecution’s case was built on circumstantial evidence. Prosecution witness Remegia Obenza testified that she saw accused-appellant Arnold Gonzales with the sleeping victim shortly before the crime. Another witness, Juny Habla, testified that Gonzales, wearing a bloodied shirt, arrived at his house around 2:00 a.m. that same day and admitted to stabbing Leolito, requesting accompaniment to surrender.
The Regional Trial Court convicted Gonzales of murder, sentencing him to reclusion perpetua and ordering him to pay indemnity. Gonzales appealed, arguing that his guilt was not proven beyond reasonable doubt due to insufficient evidence.
ISSUE
Whether the conviction of the accused-appellant based on circumstantial evidence is valid.
RULING
Yes, the conviction is valid. The Supreme Court affirmed the decision, holding that circumstantial evidence can suffice for conviction if it constitutes an unbroken chain leading to a fair and reasonable conclusion of guilt. The Court found the following circumstances formed a coherent chain: (1) Gonzales was the last person seen with the victim before his death; (2) He voluntarily confessed the stabbing to Juny Habla shortly after the incident, a statement admissible as part of the res gestae; (3) Upon discovering the victim, Gonzales made an indifferent statement, displaying apathy inconsistent with innocence; and (4) He fled after the incident, which is indicative of guilt.
The Court emphasized that the testimony of Juny Habla was credible, unrebutted due to the defense’s waiver of cross-examination, and not shown to be motivated by ill will. The combination of these circumstances, consistent with each other and with the hypothesis of guilt, excluded any reasonable doubt of Gonzales’s innocence. The Court also upheld the trial court’s assessment of witness credibility, finding no reason to overturn it. The penalty of reclusion perpetua and the award of civil indemnity were sustained.