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Bacerra v. People | G.R. No. 204544, July 3, 2017
Topic: Circumstantial Evidence as Basis of Guilt
Doctrine: The identity of the perpetrator of a crime and a finding of guilt may rest solely on the
strength of circumstantial evidence.
FACTS:
An information was filed against Marlon Bacerra for simple arson for which he was convicted.
The RTC found Bacerra Guilty beyond reasonable doubt of the crime of Simple Arson which
the CA affirmed in toto.
Bacerra argued that none of the prosecution’s witnesses had positively identified him as the
person who burned the nipa hut. He argues that the CA erred in upholding his conviction
based on circumstantial evidence, which, being merely based on conjecture, falls short of
proving his guilt beyond reasonable doubt. No direct evidence was presented to prove that
petitioner actually set fire to private complainant's nipa hut. Moreover, there were two (2)
incidents that occurred, which should be taken and analyzed separately.
In its Comment, respondent asserts that direct evidence is not the only means to establish
criminal liability. An accused may be convicted based on circumstantial evidence as long as
the combination of circumstances leads to the conclusion that the accused is guilty beyond
reasonable doubt.
ISSUE: w/n petitioner’s guilt was proven beyond reasonable doubt based on the circumstantial evidence
adduced during trial.
RULING: YES. The SC distinguished Direct Evidence and Circumstantial Evidence.
The difference between direct evidence and circumstantial evidence involves the relationship of the
fact inferred to the facts that constitute the offense. Their difference does not relate to the probative
value of the evidence.
Direct evidence proves a challenged fact without drawing any inference. Circumstantial evidence, on
the other hand, "indirectly proves a fact in issue, such that the factfinder must draw an inference or
reason from circumstantial evidence.
The probative value of direct evidence is generally neither greater than nor superior to
circumstantial evidence. The Rules of Court do not distinguish between "direct evidence of
fact and evidence of circumstances from which the existence of a fact may be inferred." The
same quantum of evidence is still required. Courts must be convinced that the accused is
guilty beyond reasonable doubt.
A number of circumstantial evidence may be so credible to establish a fact from which it may
be inferred, beyond reasonable doubt, that the elements of a crime exist and that the accused
is its perpetrator. There is no requirement in our jurisdiction that only direct evidence may
convict. After all, evidence is always a matter of reasonable inference from any fact that may
be proven by the prosecution provided the inference is logical and beyond reasonable
doubt.
Rule 113, Section 4 (now Rule 133) of the Rules on Evidence provides 3 requisites that should be
established to sustain a conviction based on circumstantial evidence:
Section 4. Circumstantial evidence, when sufficient. - Circumstantial evidence is
sufficient for conviction if:
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(a) There is more than one circumstance;
(b) The facts from which the inferences are derived are proven; and
(c) The combination of all the circumstances is such as to produce a conviction
beyond reasonable doubt.
The commission of a crime, the identity of the perpetrator,
78
and the finding of guilt may all be
established by circumstantial evidence.
79
The circumstances must be considered as a whole and
should create an unbroken chain leading to the conclusion that the accused authored the crime.
80
The determination of whether circumstantial evidence is sufficient to support a finding of guilt is a
qualitative test not a quantitative one.
81
The proven circumstances must be "consistent with each
other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent
with the hypothesis that he is innocent, and with every other rational hypothesis except that of guilt."
In a number of jurisprudence, the crime of simple arson was proven solely thru circumstantial
evidence, taken in its entirety.
Similarly, in this case, no one saw petitioner actually set fire to the nipa hut. Nevertheless, the
prosecution has established multiple circumstances, which, after being considered in their entirety,
support the conclusion that petitioner is guilty beyond reasonable doubt of simple arson.
First, the evidence was credible and sufficient to prove that petitioner stoned private complainant's
house and threatened to bum him.
91
Private complainant testified that he saw petitioner throwing
stones at his house and heard petitioner say, "okinam nga Lakay Fred, puuran kayo tad ta!"
92
(Vulva
of your mother, Old Fred, I'll bum you now.)
93
Petitioner's threats were also heard by private
complainant's son
94
and grandchildren.
95
Second, the evidence was credible and sufficient to prove that petitioner returned a few hours later
and made his way to private complainant's nipa hut.
96
Private complainant testified that at 4:00
a.m.,
97
he saw petitioner pass by their house and walk towards their nipa hut.
98
This was corroborated
by private complainant's son who testified that he saw petitioner standing in front of the nipa hut
moments before it was burned.
99
Third, the evidence was also credible and sufficient to prove that petitioner was in close proximity to
the nipa hut before it caught fire.
100
Private complainant testified that he saw petitioner walk to and fro in front of the nipa hut and shake
its posts just before it caught fire.
101
Private complainant's son likewise saw petitioner standing at the
side of the nipa hut before it was burned.
102
The stoning incident and the burning incident cannot be taken and analyzed separately. Instead,
they must be viewed and considered as a whole. Circumstantial evidence is like a "tapestry made up
of strands which create a pattern when interwoven."
103
Each strand cannot be plucked out and
scrutinized individually because it only forms part of the entire picture.
104
The events that transpired
prior to the burning incident cannot be disregarded. Petitioner's threat to bum occurred when he
stoned private complainant's house.

Unformatted Attachment Preview

Bacerra v. People | G.R. No. 204544, July 3, 2017 Topic: Circumstantial Evidence as Basis of Guilt Doctrine: The identity of the perpetrator of a crime and a finding of guilt may rest solely on the strength of circumstantial evidence. FACTS: • An information was filed against Marlon Bacerra for simple arson for which he was convicted. • The RTC found Bacerra Guilty beyond reasonable doubt of the crime of Simple Arson which the CA affirmed in toto. • Bacerra argued that none of the prosecution’s witnesses had positively identified him as the person who burned the nipa hut. He argues that the CA erred in upholding his conviction based on circumstantial evidence, which, being merely based on conjecture, falls short of proving his guilt beyond reasonable doubt. No direct evidence was presented to prove that petitioner actually set fire to private complainant's nipa hut. Moreover, there were two (2) incidents that occurred, which should be taken and analyzed separately. • In its Comment, respondent asserts that direct evidence is not the only means to establish criminal liability. An accused may be convicted based on circumstantial evidence as long as the combination of circumstances leads to the conclusion that the accused is guilty beyond reasonable doubt. ISSUE: w/n petitioner’s guilt was proven beyond reasonable doubt based on the circumstantial evidence adduced during trial. RULING: YES. The SC distinguished Direct Evidence and Circumstantial Evidence. The difference between direct evidence and circumstantial evidence involves the relationship of the fact inferred to the facts that constitute the offense. Their difference does not relate to the probative value of the evidence. Direct evidence proves a challenged fact without drawing any inference. Circumstantial evidence, on the other hand, "indirectly proves a fact in issue, such that the factfinder must draw an inference or reason from circumstantial evidence.” The probative value of direct evidence is generally neither greater than nor superior to circumstantial evidence. The Rules of Court do not distinguish between "direct evidence of fact and evidence of circumstances from which the existence of a fact may be inferred." The same quantum of evidence is still required. Courts must be convinced that the accused is guilty beyond reasonable doubt. A number of circumstantial evidence may be so credible to establish a fact from which it may be inferred, beyond reasonable doubt, that the elements of a crime exist and that the accused is its perpetrator. There is no requirement in our jurisdiction that only direct evidence may convict. After all, evidence is always a matter of reasonable inference from any fact that may be proven by the prosecution provided the inference is logical and beyond reasonable doubt. Rule 113, Section 4 (now Rule 133) of the Rules on Evidence provides 3 requisites that should be established to sustain a conviction based on circumstantial evidence: Section 4. Circumstantial evidence, when sufficient. - Circumstantial evidence is sufficient for conviction if: (a) There is more than one circumstance; (b) The facts from which the inferences are derived are proven; and (c) The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. The commission of a crime, the identity of the perpetrator,78 and the finding of guilt may all be established by circumstantial evidence.79 The circumstances must be considered as a whole and should create an unbroken chain leading to the conclusion that the accused authored the crime.80 The determination of whether circumstantial evidence is sufficient to support a finding of guilt is a qualitative test not a quantitative one.81 The proven circumstances must be "consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with the hypothesis that he is innocent, and with every other rational hypothesis except that of guilt." In a number of jurisprudence, the crime of simple arson was proven solely thru circumstantial evidence, taken in its entirety. Similarly, in this case, no one saw petitioner actually set fire to the nipa hut. Nevertheless, the prosecution has established multiple circumstances, which, after being considered in their entirety, support the conclusion that petitioner is guilty beyond reasonable doubt of simple arson. First, the evidence was credible and sufficient to prove that petitioner stoned private complainant's house and threatened to bum him.91 Private complainant testified that he saw petitioner throwing stones at his house and heard petitioner say, "okinam nga Lakay Fred, puuran kayo tad ta!"92 (Vulva of your mother, Old Fred, I'll bum you now.)93Petitioner's threats were also heard by private complainant's son94 and grandchildren.95 Second, the evidence was credible and sufficient to prove that petitioner returned a few hours later and made his way to private complainant's nipa hut.96 Private complainant testified that at 4:00 a.m.,97 he saw petitioner pass by their house and walk towards their nipa hut.98 This was corroborated by private complainant's son who testified that he saw petitioner standing in front of the nipa hut moments before it was burned.99 Third, the evidence was also credible and sufficient to prove that petitioner was in close proximity to the nipa hut before it caught fire.100 Private complainant testified that he saw petitioner walk to and fro in front of the nipa hut and shake its posts just before it caught fire.101 Private complainant's son likewise saw petitioner standing at the side of the nipa hut before it was burned.102 The stoning incident and the burning incident cannot be taken and analyzed separately. Instead, they must be viewed and considered as a whole. Circumstantial evidence is like a "tapestry made up of strands which create a pattern when interwoven."103 Each strand cannot be plucked out and scrutinized individually because it only forms part of the entire picture.104 The events that transpired prior to the burning incident cannot be disregarded. Petitioner's threat to bum occurred when he stoned private complainant's house. Name: Description: ...
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