This case has been cited 7 times or more.
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2015-04-22 |
MENDOZA, J. |
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| Here, the pieces of circumstantial evidence are not sufficient to convict Zapanta of the crimes charged. When the four circumstances are examined with the other evidence on record, it becomes clearer that these circumstances do not lead to a logical conclusion that Zapanta lent support to the alleged conspiracy. Moreover, there is no proof that he allowed an outsider inside the vault or that he knew of the unauthorized withdrawal of the subject title and consented to it. There is nothing to indicate that he was simply negligent in securing the safety of the subject certificate of title under his custody. If Zapanta were negligent, this would be incompatible with conspiracy because negligence denotes the absence of intent while conspiracy involves a meeting of the minds to commit a crime.[37] | |||||
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2012-06-13 |
PERALTA, J. |
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| Indeed, motive becomes material when the evidence is circumstantial or inconclusive, and there is some doubt on whether a crime has been committed or whether the accused has committed it.[19] As held in Crisostomo v. Sandiganbayan,[20] motive is generally held to be immaterial because it is not an element of the crime. However, motive becomes important when the evidence on the commission of the crime is purely circumstantial or inconclusive.[21] It is clear from the above testimonies that the victim had an encounter with a group of people in the street before all of them scampered and only petitioner was left behind. Thus, motive on the part of the petitioner has been established through the testimonies of the witnesses presented narrating the incident in which the victim slapped the petitioner and hit him with a bamboo stick before they went to the same direction. | |||||
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2012-02-01 |
SERENO, J. |
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| In Crisostomo v. Sandiganbayan,[45] the Sandiganbayan set the hearing of the defense's presentation of evidence for 21, 22 and 23 June 1995. The 21 June 1995 hearing was cancelled due to "lack of quorum in the regular membership" of the Sandiganbayan's Second Division and upon the agreement of the parties. The hearing was reset for the next day, 22 June 1995, but Crisostomo and his counsel failed to attend. The Sandiganbayan, on the very same day, issued an Order directing the issuance of a warrant for the arrest of Crisostomo and the confiscation of his surety bond. The Order further declared that he had waived his right to present evidence because of his nonappearance at "yesterday's and today's scheduled hearings." In ruling against the Order, we held thus: Under Section 2(c), Rule 114 and Section 1(c), Rule 115 of the Rules of Court, Crisostomo's non-appearance during the 22 June 1995 trial was merely a waiver of his right to be present for trial on such date only and not for the succeeding trial dates... | |||||
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2007-03-30 |
AUSTRIA-MARTINEZ, J. |
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| And when the evidence on the commission of the crime is purely circumstantial or inconclusive, motive is vital. As held in Crisostomo v. Sandiganbayan,[57] | |||||
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2007-03-30 |
AUSTRIA-MARTINEZ, J. |
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| That Galvez was a police officer who could have justified his presence at the scene of the crime with a lawful purpose, yet he put up an alibi which is inherently weak; and that Galvez did not present his wife and father-in-law as witnesses to corroborate his story that he was at their house on the night in question, pertain to the weakness of Galvez's alibi which may cast doubt on his innocence. However, these circumstances do not prove beyond reasonable doubt Galvez's guilt. Although an accused must satisfactorily prove his alibi, the burden in criminal cases still rests on the prosecution to prove the accused's guilt. The prosecution evidence must stand or fall on its own weight and cannot draw strength from the weakness of the defense. Unless the prosecution overturns the constitutional presumption of innocence of an accused by competent and credible evidence proving his guilt beyond reasonable doubt, the presumption remains.[78] Courts must judge the guilt or innocence of the accused based on facts and not on mere conjectures, presumptions, or suspicions.[79] | |||||
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2006-08-16 |
AUSTRIA-MARTINEZ, J. |
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| Courts must judge the guilt or innocence of the accused based on facts and not on mere conjectures, presumptions, or suspicions.[38] Other than the plain fact that the victim had been shot by one of the accused while being held by a co-accused, there is no other evidence that the appellants were animated by the same purpose or were moved by a previous common accord. It follows that the liability of the accused must be determined on an individual basis. While no formal agreement is necessary to establish conspiracy because conspiracy may be inferred from the circumstances attending the commission of the crime, yet, conspiracy must be established by clear and convincing evidence.[39] | |||||
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2006-08-16 |
AUSTRIA-MARTINEZ, J. |
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| This Court has held that even if all the malefactors joined in the killing, such circumstance alone does not satisfy the requirement of conspiracy because the rule is that neither joint nor simultaneous action is per se sufficient proof of conspiracy. Conspiracy must be shown to exist as clearly and convincingly as the commission of the offense itself.[40] Thus, even assuming that Javier was simultaneously attacked, this does not prove conspiracy. No evidence was presented to show that the appellants planned to kill Javier or that Dagani's overt acts facilitated that alleged plan. The prosecution did not establish that the act of Dagani in trying to wrestle the gun from Javier and in the process, held the latter's hands, was for the purpose of enabling Santiano to shoot at Javier. The prosecution had the burden to show Dagani's intentional participation to the furtherance of a common design and purpose[41] or that his action was all part of a scheme to kill Javier. That Dagani did not expect Santiano to shoot the victim is established when Santiano testified that Dagani "seem[ed] to be shocked, he was standing and looking at the victim" as Javier gradually fell to the ground.[42] And since Dagani's conviction can only be sustained if the crime had been carried out through a conspiracy duly proven, in view of the failure of the prosecution to discharge that burden, this Court is constrained to acquit him. | |||||