G.R. No. L-38162 May 17, 1980
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VICENTE PAJANUSTAN, accused-appellant.

FACTS

In the evening of December 1, 1970, spouses Jesusimo and Simeona Aco and their two young grandsons were brutally murdered in their home in Las Navas, Northern Samar. The perpetrators also robbed the house of cash and valuables totaling seven hundred twenty pesos. The victims suffered multiple fatal stab wounds. The accused, Vicente Pajanustan, admitted he and two companions were fed and lodged in the victims’ house that night. He was charged with robbery with homicide but claimed his companions alone committed the crimes; he allegedly fled when the killings began out of fear.
At trial, Pajanustan maintained his innocence, asserting he tried to dissuade one companion and then escaped. The trial court acquitted his co-accused cousin but convicted Pajanustan of robbery with homicide, finding the crime aggravated by treachery and abuse of confidence, and imposed the death penalty. The case was elevated to the Supreme Court for automatic review.

ISSUE

The core issue is whether the circumstantial evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that Vicente Pajanustan conspired and actively participated as a principal in the commission of the special complex crime of robbery with homicide.

RULING

The Supreme Court affirmed the conviction, holding that the totality of circumstantial evidence conclusively established Pajanustan’s guilt. The Court meticulously applied the rules on circumstantial evidence, which require more than one circumstance, proven facts as a basis for inferences, and a combination producing conviction beyond reasonable doubt. Pajanustan’s judicial admission of his presence at the crime scene was pivotal.
The Court found the testimony of witness Julio Nungay highly credible. Nungay encountered Pajanustan and two armed companions near the crime scene shortly after midnight, with Pajanustan exhibiting a bloodstain on his shirt and acting nervously by asking for directions to a trail he already knew. This nervousness and confusion were indicative of recent participation in a grave crime. This evidence directly contradicted Pajanustan’s alibi of having fled earlier. The Court further considered his flight, eight-month period in hiding, failure to report the incident, and his criminal record as corroborative inculpatory circumstances. The combination of these facts formed an unbroken chain leading to the sole rational conclusion that Pajanustan was a co-conspirator. The Court also affirmed the presence of the aggravating circumstances of treachery (attack on sleeping victims) and abuse of confidence (hospitality betrayed), justifying the imposition of the death penalty. The judgment was modified to include an order for Pajanustan to indemnify the heirs for the value of the stolen property.