G.R. No. 209137 , July 1, 2015
EDUARDO CELEDONIO, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Eduardo Celedonio was charged with Robbery with Force Upon Things for allegedly entering the house of Carmencita De Guzman on April 22, 2007, by destroying the backdoor, and stealing various items and cash totaling approximately Php223,000. The prosecution presented Adriano Marquez, a neighbor who witnessed the robbery and identified Celedonio as the perpetrator. During a follow-up operation, police officers PO1 Rommel Roque and SPO2 Adrian Sugui, accompanied by Marquez, flagged down Celedonio on his motorcycle. When asked about the stolen items, Celedonio opened his motorcycle compartment, revealing some of the stolen goods, including a portable DVD player and a wristwatch. He was arrested, and more items were later seized at the police station. Celedonio filed a Demurrer to Evidence, arguing illegal arrest and search, but the Regional Trial Court (RTC) denied it, noting his arraignment and participation in the trial mooted the issue. The RTC convicted Celedonio based on circumstantial evidence, including his proximity to the crime scene, Marquez’s testimony, his possession of recently stolen items, and his lack of valid explanation for such possession. The Court of Appeals affirmed the RTC decision.

ISSUE

1. Whether the Court of Appeals erred in affirming the conviction based on circumstantial evidence.
2. Whether the search conducted on Celedonio was illegal, rendering the seized items inadmissible.
3. Whether the prosecution witness Adriano Marquez was ill-motivated in testifying against Celedonio.

RULING

The Supreme Court denied the petition, upholding the conviction.
1. On circumstantial evidence: The Court ruled that circumstantial evidence was sufficient for conviction under Section 4, Rule 133 of the Rules of Court, as there was more than one circumstance, the facts were proven, and their combination produced conviction beyond reasonable doubt. The circumstances included Celedonio being a next-door neighbor, Marquez witnessing him ransacking the house, the stolen items found in his motorcycle compartment, and his failure to explain his possession. These formed an unbroken chain leading to the conclusion that he committed the robbery.
2. On the legality of the search: The Court held that the search was not illegal. Celedonio voluntarily opened his motorcycle compartment when asked about the stolen items, and the items were in plain view. His failure to question the legality of his arrest before arraignment constituted a waiver. Moreover, the search of a moving vehicle falls under recognized exceptions to the warrant requirement.
3. On the witness’s motivation: The Court found no evidence that Marquez was ill-motivated. Celedonio’s claim that Marquez had a grudge over a water meter dispute was unsupported. Absent proof of improper motive, Marquez’s testimony was deemed credible. Celedonio’s defenses of alibi and denial could not prevail over the strong circumstantial evidence. The RTC and CA’s factual findings were upheld, as no overlooked facts warranted a different ruling.