## FACTS:

Accused-appellant Yip Wai Ming and victim Lam Po Chun, both Hongkong nationals, arrived in Manila on vacation. They were engaged to be married. Lam Po Chun was found dead in their hotel room, and an autopsy revealed that the cause of death was asphyxia by strangulation. Prior to her death, Lam Po Chun had an insurance policy with accused-appellant as the beneficiary. The appellant and Lam Po Chun had a romantic relationship and had plans to get married. On the day of the killing, accused-appellant received a phone call informing him that visitors had arrived, and he went to meet them while Lam Po Chun stayed in the room due to a headache. Accused-appellant claims to have instructed the front desk to provide Lam Po Chun with medicine and not to disturb her. The prosecution alleged that accused-appellant killed Lam Po Chun for the insurance proceeds, while the defense argued that there was no concrete evidence to prove the existence of the insurance policy and accused-appellant's motive for the crime.

ISSUES

The main issue in this case was whether the circumstantial evidence linking the accused-appellant, Yip Wai Ming, to the killing of Lam Po Chun was sufficient to sustain a judgment of conviction beyond reasonable doubt.

RULING

The Supreme Court held that the circumstantial evidence presented against the accused-appellant was not sufficiently credible and unbroken to warrant a conviction. The Court found significant flaws in key elements of the prosecution's case, including the supposed motive for the crime and the time of death of the victim. The Court observed inconsistencies and uncertainties in the evidence presented and determined that the motive built around a life insurance policy was not substantiated with reliable evidence. Moreover, the time of death could not be conclusively determined within a narrow time frame, casting doubt on the accused's opportunity to commit the crime. Consequently, the Supreme Court reversed the decision of the trial court and acquitted Yip Wai Ming on the ground of reasonable doubt.

PRINCIPLES

1. Burden of Proof: Circumstantial evidence must be sufficiently strong to support a guilty verdict beyond reasonable doubt.

2. Unbroken Chain of Evidence: Circumstantial evidence must form an unbroken chain which leads only to the conclusion of the guilt of the accused, excluding all other possibilities.

3. Motive and Opportunity: The presence of motive and opportunity play a crucial role in cases relying heavily on circumstantial evidence.

4. Exclusion of All Reasonable Hypotheses Except That of Guilt: Every hypothesis except that of guilt must be excluded to convict on circumstantial evidence.

5. Right to Due Process: Custodial interrogations must respect and adhere to the constitutional rights of the accused, including the right to be informed of rights and to have competent and independent counsel during the interrogation.

These principles reflect the high threshold that must be met in criminal proceedings where the accused's liberty is at stake, particularly in cases resting on circumstantial evidence.