G.R. No. L-64508 March 19, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MIGUEL LASAC, defendant-appellant.

FACTS

Miguel Lasac was convicted of parricide for the killing of his wife, Maria Consolacion Garcia, and sentenced to life imprisonment by the Court of First Instance of Oriental Mindoro. The prosecution’s case was built on circumstantial evidence and an extrajudicial confession (Exhibit B). The victim was found dead on March 15, 1980, with multiple stab wounds, near their conjugal dwelling. No eyewitnesses existed. Circumstances included Lasac’s prior threat about his wife, his refusal to let her father see her on the morning of the crime, his sighting going towards the crime scene, his restless behavior and lack of remorse after the body’s discovery, and the wet condition of his bolo and clothing. Lasac appealed, arguing his affidavit was inadmissible as it was obtained without counsel and through force, and that the circumstantial evidence was insufficient for conviction. Notably, the Solicitor General joined the prayer for acquittal.

ISSUE

The core issue was whether the circumstantial evidence, absent the contested affidavit, was sufficient to prove Lasac’s guilt beyond reasonable doubt for parricide.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Miguel Lasac. The Court held the affidavit of admission (Exhibit B) was inadmissible as it was executed without the assistance of counsel, violating his constitutional rights. Consequently, this principal evidence for the prosecution failed. The remaining circumstantial evidence was deemed insufficient to meet the required standard of proof. For a conviction based on circumstantial evidence, the circumstances must form an unbroken chain leading to one reasonable conclusion pointing to the accused’s guilt to the exclusion of all others. The evidence presented—such as his prior statement, movements, and behavior—did not constitute an unbroken chain excluding every other reasonable hypothesis of innocence. The Court emphasized that where the principal evidence fails, all corroborative evidence intended to support it must likewise fail. Since the evidence did not produce moral certainty of guilt, the presumption of innocence prevailed.