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People v.

Padua | February 23, 2007 and (3) the combination of all the
circumstances is such as to produce a
Facts: conviction beyond reasonable doubt. All the
Christopher Padua, Alejandro Padua and circumstances must be consistent with each
Michael Dullavin were charged with rape with other, consistent with the hypothesis that the
homicide of a 10 year old minor XXX. XXXs accused is guilty, and at the same time
younger brothers YYY and ZZZ testified that inconsistent with the hypothesis that he is
they saw the three carry their older sister innocent.
away while they were walking home in Thus, conviction based on circumstantial
Muntinlupa and that her mouth was covered evidence can be upheld, provided the
to keep her from crying out. They were able to circumstances proven constitute an unbroken
positively identify the three suspects because chain which leads to one fair and reasonable
the place where XXX was taken from was conclusion that points to the accused, to the
illuminated by billboard lights. XXX was found exclusion of all others, as the guilty person.
dead 2 days later in Pacita Complex, San
Pedro, Laguna, with her clothes strewn In this case, all the circumstantial evidence
around her body. An examination of the body that were presented have been duly proven
found that XXX was raped. The three and established. the prosecution was able to
interposed an alibi that they were in Alabang establish the appellants culpability through
when the incident took place. The lower court the established facts which constitute an
found the three guilty, and sentenced them to unbroken chain of events leading to the
death. Later on it was found that Christopher conclusion of guilt on the part of the
was a minor at the time of the crime, and his appellants. There is thus moral certainty that
sentence was reduced to reclusion perpetua. they authored the crime charged. And even
Alejandros sentence was also reduced to though the appellants contended that the
reclusion perpetua since he was already 72 witnesses were not credible, the court found
years old at the time of the commission of the their narration of the events to be consistent
crime. even after rigorous cross examination by 3
defense counsels. Lastly, their alibi did not
Issue: hold up, as they were not able to show that it
WON the guilt of the three accused was was physically impossible for them to be at
proven beyond reasonable doubt. the scene of the crime at the time of its
commission.
Held:
YES. Direct evidence of the commission of a
crime is not the only matrix wherefrom a trial
court may draw its conclusion and finding of
guilt. The rules of evidence allow a trial court
to rely on circumstantial evidence to support
its conclusion of guilt. Circumstantial evidence
is that evidence which proves a fact or series
of facts from which the facts in issue may be
established by inference.

Section 4 of Rule 133 of the Rules of Court


provides that circumstantial evidence is
sufficient for conviction if the following
requisites are complied with: (1) there is more
than one circumstance; (2) the facts from
which the inferences are derived are proven;