GR 92968; (December, 1991) (Digest)
G.R. No. 92968 , December 2, 1991
People of the Philippines vs. Zosimo Alabaso
FACTS
The accused-appellant, Zosimo Alabaso, was convicted of murder for the killing of his business partner, Angel Gonzales, on November 5, 1987, in Bongabon, Nueva Ecija. The prosecution’s evidence was circumstantial. It established that Alabaso and the victim were partners in a tricycle buy-and-sell business. On the evening of the incident, they had a drinking session at the house of Andres Velarde, during which an argument erupted over commission payments. After the session, with Gonzales intoxicated, Alabaso insisted on driving him home using the victim’s own tricycle.
The defense presented a different narrative. Alabaso claimed that while driving home, three armed men blocked their path. An argument ensued, he was struck and lost consciousness, and when he awoke, Gonzales was already injured. He then brought the victim to the hospital, where Gonzales was pronounced dead.
ISSUE
Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant beyond reasonable doubt.
RULING
Yes, the Supreme Court affirmed the conviction. The Court meticulously applied the rules on circumstantial evidence, which require: (a) more than one circumstance; (b) proven facts from which inferences are derived; and (c) a combination of circumstances producing conviction beyond reasonable doubt. The prosecution successfully established an unbroken chain of circumstances: the prior argument over money, Alabaso’s insistence on driving the intoxicated victim home alone, the eyewitness account of a person (Matutino) who saw Alabaso hitting someone with a blunt object at the specific location and time consistent with the crime, and the medical finding that death resulted from blows to the head with a blunt instrument.
The Court found these circumstances, when considered collectively, to be consistent with each other and wholly inconsistent with any reasonable hypothesis of innocence, including Alabaso’s claim of an attack by third parties. His flight and evasion of arrest for over a year further undermined his defense. Consequently, the trial court’s judgment was upheld, with the modification of increasing the civil indemnity to the heirs to Fifty Thousand Pesos (P50,000.00).