G.R. No. 193837 SEPTEMBER 21, 2016
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RENATO M. PANGAN, ACCUSED-APPELLANT.

FACTS

Accused-appellant Renato Pangan was charged with Robbery with Homicide for the killing of Rodolfo Ocampo and the taking of his personal belongings, including a cellphone. The prosecution’s case was built entirely on circumstantial evidence. Witness Ernesto Aguinaldo testified that he saw the victim and appellant together near the victim’s hut on the afternoon of August 21, 2003. The victim’s decomposing body was discovered in the locked hut days later. Michael Aragon stated that on August 22, 2003, appellant was in possession of a Nokia 3310 cellphone containing the names “Rowena” and “Rudy” (the victim’s nickname) in its directory. Appellant sought help reloading the phone and would turn it off when it rang. Police later recovered the phone from a witness, Rialyn Napicog, who claimed appellant gave it to her. SPO1 Rosby Ramos testified that appellant led them to the recovery of the phone’s SIM card. The victim’s son-in-law, Mauricio Magtoto, also claimed appellant confessed to the killing in the presence of family and a barangay official, though no corroborating sworn statements were presented.
The defense presented an alibi, with appellant denying the accusations and claiming he was at home with his siblings on the date of the incident. He alleged that the police coerced him into admitting the crime. The Regional Trial Court convicted Pangan of Robbery with Homicide and sentenced him to reclusion perpetua, a decision affirmed by the Court of Appeals. Both courts held that the totality of the circumstantial evidence established his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming appellant’s conviction for Robbery with Homicide based on circumstantial evidence.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED appellant Renato Pangan. The Court held that the prosecution failed to prove his guilt beyond reasonable doubt, as the circumstantial evidence presented did not constitute an unbroken chain leading to the inescapable conclusion of his guilt. For circumstantial evidence to suffice, each circumstance must be proven, consistent with the hypothesis of guilt, and inconsistent with innocence. The Court found critical gaps in the evidence chain.
First, the alleged extrajudicial confession recounted by Magtoto was unreliable. It was not reduced to writing by any official, and none of the alleged witnesses, including the barangay chairman, executed affidavits to corroborate it. Second, the evidence of possession of stolen property was tenuous. The prosecution failed to conclusively establish that the cellphone presented in court was the same one stolen from the victim. The chain of custody was broken; the phone was not properly marked upon recovery and its identity was not preserved with certainty. Furthermore, the alleged confession to Magtoto and the possession of the phone, even if accepted, did not directly prove that appellant killed the victim on the occasion of a robbery. No evidence placed appellant at the precise scene at the time of death, and the supposed motive of robbery was not firmly established. The circumstances, taken together, did not exclude every reasonable hypothesis except that of guilt. Therefore, the constitutional presumption of innocence prevailed, mandating acquittal.