G.R. No. 77713 February 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO AGAN alias JIMMY, defendant-appellant.

FACTS

The accused, Alfredo Agan, was charged with Murder for the stabbing death of Nemencio Uy on August 19, 1982, in Pulilan, Bulacan. The Information alleged the killing was attended by evident premeditation, abuse of superior strength, and treachery, as the victim was allegedly sleeping. Upon arraignment, Agan pleaded not guilty. His defense was one of denial and frame-up, claiming that a co-worker, Nelson Fabroa, was the actual assailant. He testified that he merely witnessed an argument between Fabroa and Uy, saw the stabbing, and then fled when Fabroa turned on him. The trial court rejected this defense, finding Agan guilty of murder and sentencing him to reclusion perpetua.
On appeal, Agan contended that the prosecution evidence was purely circumstantial and insufficient to prove his guilt beyond reasonable doubt. He argued that such evidence could not prevail over his positive testimony denying involvement.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to sustain a conviction for the killing of Nemencio Uy.

RULING

Yes, the circumstantial evidence is sufficient for conviction, but the crime committed is Homicide, not Murder. The Supreme Court affirmed the conviction with modifications. The Court meticulously applied the rules on circumstantial evidence under the Rules of Court, which require: (1) more than one circumstance; (2) the facts from which inferences are derived are proven; and (3) the combination of all circumstances produces conviction beyond reasonable doubt. The prosecution established a chain of incriminating circumstances: (1) The victim was seen emerging from a house with a fatal chest wound; (2) Moments later, Agan was seen exiting the same house holding a blood-stained knife; (3) The knife used in the stabbing was recovered from Agan, a fact he did not controvert; (4) Agan admitted his presence at the crime scene when the incident occurred; and (5) The prosecution witnesses were credible and had no motive to falsely testify. The combination of these facts leads to the inescapable conclusion that Agan perpetrated the killing.
However, the Court agreed with the Solicitor General that the qualifying circumstances of evident premeditation, abuse of superior strength, and treachery alleged in the Information were not proven. The record was devoid of evidence showing how the attack was commenced or that the victim was asleep, thus the crime is properly Homicide under Article 249 of the Revised Penal Code. The penalty was modified to an indeterminate sentence of eight years and one day of prision mayor, as minimum, to fourteen years, eight months, and one day of reclusion temporal, as maximum. Civil indemnity was increased to P30,000.00.