SALVADOR V. PEOPLE (CRIMINAL, EVIDENCE)

Direct evidence of the 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. At times, resort to circumstantial evidence is imperative since to insist on direct testimony would in many cases result in setting felons free and deny protection to the community.

Section 4, 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; and
3. the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.

All the circumstances must be consistent with one another, consistent with the hypothesis that the accused is guilty and at the same time, inconsistent with the hypothesis that he is innocent. Thus, conviction based on circumstantial evidence can be upheld, provided that the circumstances constitute an unbroken chain which leads to one fair and reasonable conclusion that points to the accused to the exclusion of all others, as the guilty person.

Also, it is a rule in criminal law that MOTIVE being a state of mind, is established by the testimony of witnesses on the acts or statements of the accused before or immediately after the commission of the offense, deeds, or words that may express it or from which his motive or reason for committing it may be inferred. Motive and intent may be considered one and the same, in some instances, as in the present case.

In view of the foregoing, petitioner was correctly convicted of homicide punishable by reclusion temporal.