G.R. No. 84423 . January 31, 1989.
JOSE NAVARRO Y BORLONGAN, petitioner, vs. THE HONORABLE COURT OF APPEALS and THE PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Jose Navarro, a barangay captain, was charged with murder for the killing of Patrolman Leonardo Enriquez. The incident occurred on December 29, 1983, at a beach resort in Limay, Bataan, during a gathering Navarro had invited the victim to attend. The prosecution’s case, built primarily on the testimony of Pat. Florante Mendoza, a fellow policeman and companion of the victim, established that a heated argument ensued between Navarro and Enriquez, during which Enriquez collared Navarro. After being pacified, Navarro and co-accused Nestor Quezon left the resort.
Approximately thirty minutes later, Navarro and Quezon returned in a Volkswagen Beetle with an unidentified man, “Alias Talao.” Suddenly, Talao shot Enriquez from behind. As Mendoza reacted, Navarro wrested Mendoza’s service pistol and shouted to Talao, “sibat na” (let’s go). Navarro then forced Mendoza onto a tricycle, returned the pistol after removing its bullets, and warned Mendoza not to report the incident under threat to his family’s safety.

ISSUE

Whether the conviction of Jose Navarro, based primarily on the uncorroborated circumstantial testimony of a single witness, Pat. Mendoza, is valid.

RULING

Yes, the conviction is valid. The Supreme Court affirmed the Court of Appeals’ modification, finding Navarro guilty as a co-principal in the crime of Homicide. The legal logic rests on the sufficiency of circumstantial evidence to establish guilt beyond reasonable doubt. The Court emphasized that conviction can be based on circumstantial evidence provided: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination of all circumstances produces a conviction beyond moral certainty.
Here, the series of proven acts formed a coherent and unbroken chain leading to the reasonable conclusion that Navarro cooperated in the killing with a community of criminal purpose. His actions before, during, and after the shooting—leaving after the altercation, returning with the gunman, disarming the witness to facilitate the escape, and threatening the witness to prevent reporting—demonstrated concerted action indicative of conspiracy. The fact that the testimony came from a single witness does not invalidate the conviction, as the witness was present and testified to multiple material circumstances that corroborated each other. The Court found no reason to doubt Mendoza’s credibility, and Navarro’s own actions supplied the necessary corroboration, fulfilling the requirements for circumstantial evidence. The mitigating circumstance of passion and obfuscation was correctly appreciated due to the prior physical provocation (being collared by the victim).