This case has been cited 6 times or more.
2014-06-09 |
DEL CASTILLO, J. |
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Truly, "direct evidence of the commission of a crime is not the only basis from which a court may draw its finding of guilt."[27] 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 indirectly proves a fact in issue through an inference which the fact-finder draws from the evidence established."[28] Under Section 4, Rule 133 of the Rules of Court, circumstantial evidence would be sufficient to convict the offender "if i) there is more than one circumstance; ii) the facts from which the inference is derived are proven; and iii) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt."[29] 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 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.[30] | |||||
2013-09-18 |
DEL CASTILLO, J. |
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"[C]ircumstantial evidence is sufficient to sustain a conviction if (i) there is more than one circumstance; (ii) the facts from which the inference is derived are proven; and (iii) the combination of all circumstances is such as to produce conviction beyond reasonable doubt."[33] All the foregoing elements were sufficiently established in this case. | |||||
2012-09-11 |
PEREZ, J. |
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In a complex crime, two or more crimes are actually committed, however, in the eyes of the law and in the conscience of the offender they constitute only one crime, thus, only one penalty is imposed. There are two kinds of complex crime. The first is known as compound crime, or when a single act constitutes two or more grave or less grave felonies while the other is known as complex crime proper, or when an offense is a necessary means for committing the other. The classic example of the first kind is when a single bullet results in the death of two or more persons. A different rule governs where separate and distinct acts result in a number killed. Deeply rooted is the doctrine that when various victims expire from separate shots, such acts constitute separate and distinct crimes.[80] | |||||
2011-07-27 |
LEONARDO-DE CASTRO, J. |
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Article 48 of the Revised Penal Code provides that "[w]hen a single act constitutes two or more grave or less grave felonies, or when an offense is a necessary means for committing the other, the penalty for the most serious crime shall be imposed, the same to be applied in its maximum period." There are, thus, two kinds of complex crimes. The first is known as compound crime, or when a single act constitutes two or more grave or less grave felonies. The second is known as complex crime proper, or when an offense is a necessary means for committing the other.[61] | |||||
2010-06-29 |
VELASCO JR., J. |
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In a complex crime, although two or more crimes are actually committed, they constitute only one crime in the eyes of the law, as well as in the conscience of the offender. Hence, there is only one penalty imposed for the commission of a complex crime.[50] | |||||
2010-04-23 |
VELASCO JR., J. |
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In the absence of evidence showing the direct participation of the accused in the commission of the crime, conspiracy must be established by clear and convincing evidence in order to convict the accused.[136] Given our observation that the involvement of Rosales was not merely of a person under coercion, there is reasonable doubt as to Bobby Bringas' involvement for it was Jimboy Bringas who brought or recruited Sulayao and Calaguas from Pampanga. There is therefore a palpable reasonable doubt of the existence of conspiracy on the part of Bobby Bringas. The presence of reasonable doubt as to the existence of conspiracy suffices to negate not only the participation of the accused in the commission of the offense as principal but also, in the absence of proof implicating the accused as accessory or accomplice, the criminal liability of the accused.[137] Consequently, Bobby Bringas must be acquitted from the crime of kidnapping for ransom. |