G.R. No. 187725; January 19, 2011
BENJAMIN JESALVA, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

On September 11, 1992, a criminal complaint for Frustrated Murder was filed against petitioner Benjamin Jesalva after an incident involving Leticia Aldemo. The complaint was amended to Murder on September 15, 1992, following Leticia’s death on September 14, 1992. An Information dated January 26, 1993, charged Jesalva with Murder, alleging that on or about September 9, 1992, in Sorsogon, with intent to kill, treachery, and evident premeditation, he attacked and inflicted mortal wounds upon Leticia Aldemo, causing her death.
The prosecution’s version established that on the evening of September 8, 1992, Jesalva, the victim Leticia Aldemo, and others were together playing mahjong and later ate and drank at Bistro Christina. Jesalva drove the group home in his Isuzu panel. After dropping off others, Jesalva and Aldemo were last seen together. Around 12:20 a.m. on September 9, 1992, SPO1 Edgardo Mendoza, while on patrol, saw Jesalva alone in his vehicle in St. Rafael Subdivision; when called, Jesalva sped away toward the town proper instead of his home direction. Separately, a witness, Noel Olbes, found a woman (later identified as Aldemo) naked from the waist down and bleeding on the highway; he moved her to a shed. Another witness, tricycle driver Eduardo De Vera, reported the incident to police. Jesalva “surrendered” at the police station at 1:00 p.m. on September 9, accompanied by his cousin, Fiscal Jose Jayona, and told SPO4 William Desder that Leticia had jumped out of his vehicle. Police inspection of the location Jesalva pointed to revealed bloodstains. The prosecution also presented testimony that Jesalva was courting Aldemo, but she rejected him as she was married.
The defense presented Jesalva, who denied killing Aldemo, stating he had no reason to do so. Witness Eduardo de Vera testified that around 12:30 a.m. on September 9, he saw a man and a woman near the road; the woman was leaning on the man, who was squatting and hiding his face, and he saw little blood on the woman’s clothes.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Benjamin Jesalva’s conviction for Homicide based on circumstantial evidence.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Court of Appeals’ Decision with MODIFICATION. The CA correctly affirmed the Regional Trial Court’s finding of guilt but modified the conviction from Murder to Homicide. The Supreme Court held that the totality of the circumstantial evidence presented by the prosecution sufficiently established Jesalva’s guilt beyond reasonable doubt for the killing of Leticia Aldemo.
The circumstantial evidence, when taken together, forms an unbroken chain leading to the reasonable conclusion that Jesalva was the perpetrator. The evidence includes: (1) Jesalva was the last person seen with the victim alive; (2) his flight when encountered by police in the early morning near the crime scene; (3) his statement to police that the victim “jumped” from his vehicle; (4) the location he pointed to matched where the victim was found and where bloodstains were discovered; and (5) the medical finding of “vaginal fresh laceration” consistent with sexual assault, supporting a possible motive linked to his courtship being rejected. His denial and the defense witness’s account were insufficient to overcome the prosecution’s evidence. However, the qualifying circumstances of treachery, evident premeditation, and abuse of superior strength were not proven with certainty; hence, the crime is Homicide, not Murder. The Court modified the awarded damages accordingly.