Circumstantial Evidence in Qualified Theft cases. – “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.32 Circumstantial evidence suffices to convict an accused only if the circumstances proven constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused, tothe exclusion of all others, as the guilty person; the circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and, at the same time, inconsistent with any other hypothesis except that of guilt. Corollary thereto, a conviction based on circumstantial evidence must exclude each and every hypothesis consistent with innocence.”([1]Citations omitted)
“It bears to add that when evidence of theft is circumstantial as in this case, proof as to motive, that is, intent to gain, is essential and cannot be merely inferred. “Animus lucrandi or intent to gain is an internal act which can be established through the overt acts of the offender.”[2]
“It is well settled that before conviction can be based on circumstantial evidence, the circumstances proved should constitute an unbroken chain of events which leads to one fair and reasonable conclusion pointing to the defendant, to the exclusion of others, as the author of the crime. Thus, the following requisites must be met: 1) there must be more than one circumstance; 2) the facts from which the inferences are derived are proven; 3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt.[3]
“Circumstantial evidence is not a “weaker” form of evidence vis-à-vis direct evidence. The Rules of Court do not distinguish between direct evidence and evidence of circumstances insofar as their probative value is concerned. No greater degree of certainty is required when the evidence is circumstantial than when it is direct, for in either case, the trier of fact must be convinced beyond a reasonable doubt as to the guilt of the accused
Under Section 4, Rule 133 of the Revised Rules of Court, circumstantial evidence is sufficient for conviction if there is more than one circumstance, the facts from which the inference is derived, are proven, and the combination of all the circumstances produces moral certainty as to convict beyond a reasonable doubt.”[4]
Circumstantial evidence suffices to convict an accused only if the circumstances proved 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; the circumstances proved must be consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with any other hypothesis except that of guilty.[5]
“While it is true that there was no eyewitness when the petitioner committed the crime of qualified theft, it does not necessarily follow that her guilt was not proven beyond reasonable doubt. It should be emphasized that an accused can be convicted even if no eyewitness is available, as long as sufficient circumstantial evidence had been presented by the prosecution to prove beyond reasnable doubt that the accused committed the crime.”[6] (Citations omitted)
[1] Candelaria v. People, G.R. No. 209386, December 8, 2014; People v. Tanchangco, G.R. No. 177761, April 18, 2012
[2] Imperial v. People, G.R. No. 230519, June 30, 2021, citing Medina v. People, 486 Phil. 288 and People v. Reyes, 447 Phil. 668 (2004)
[3] People v. Bago, G.R. No. 122290, April 6, 2000, citing People v. Maqueda, 242 SCRA 565 and People v. Cadevida, et al., 219 SCRA 218
[4] People v. Sison, G.R. No. 123183, January 19, 2000
[5] People v. Castro, G.R. No. 170415, September 19, 2008, cited in People v. Bayon, G.R. No. 168627, July 2, 2010
[6] Rebucan v. People, G.R. No. 164545, November 20, 2006