G.R. No. 228951 , July 17, 2019
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JAY GODOY MANCAO, Accused-Appellant

FACTS

Accused-appellant Jay Godoy Mancao was charged with Robbery with Homicide for the killing of Peter Ray Garcia Enriquez on September 2, 2007, in Davao City. The prosecution presented eyewitness Manuel Bernido, Jr., who testified that around 3:30 a.m., he saw appellant suddenly approach the victim from behind and stab him in the neck. Appellant then dragged the victim toward an alley. Bernido later saw appellant washing away blood stains. The police investigation, led by SPO2 Kelvin Magno, discovered the victim’s body missing his cellphone, jewelry, and wallet. A trail of blood led to the boarding house of the Mancao brothers. Appellant’s brother, Wangyu, confessed to assisting appellant in fleeing. Appellant was later arrested in Maco, Davao del Norte, and a silver necklace identified by the victim’s father was found in his possession, along with blood-stained pants.
The defense consisted solely of appellant’s denial and alibi, claiming he was in Compostela Valley tending to his mother’s land since September 1, 2007, and that he was arrested without a warrant and forced to wear the necklace. The Regional Trial Court convicted appellant of Robbery with Homicide and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction but modified the damages awarded.

ISSUE

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

RULING

The Supreme Court denied the appeal and affirmed the conviction. The legal logic rests on the sufficiency of circumstantial evidence to establish guilt beyond reasonable doubt for the complex crime of Robbery with Homicide. The Court emphasized that a conviction can be based on circumstantial evidence if the following concur: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all the circumstances produces a conviction beyond reasonable doubt.
Here, the proven circumstances formed an unbroken chain leading to the reasonable conclusion that appellant was the perpetrator. These included: (1) Bernido’s positive eyewitness account of the stabbing and appellant’s subsequent actions; (2) the discovery of the victim’s body missing his personal belongings; (3) the blood trail leading to appellant’s residence; (4) the confession of appellant’s brother regarding his involvement and assistance in flight; (5) appellant’s attempted escape upon arrest; and (6) the recovery of the victim’s necklace in appellant’s possession and his blood-stained pants. The killing was logically committed by reason or on the occasion of the robbery, as the evidence showed no prior motive between appellant and the victim other than the taking of the latter’s belongings. Appellant’s defense of alibi, uncorroborated and inherently weak, could not prevail over the positive and circumstantial evidence presented by the prosecution. The penalty of reclusion perpetua was correctly imposed. The monetary awards were modified in accordance with prevailing jurisprudence.