FACTS:

In Criminal Case No. 98-163090, Danilo Asis and Gilbert Formento were found guilty by the Regional Trial Court (RTC) of Manila for robbery with homicide. The accused were charged with stabbing and robbing the victim, Yu Hing Guan, and were sentenced to death. The prosecution presented circumstantial evidence, including testimonies from witnesses, the discovery of the victim's shorts in Formento's bag, and the victim's sister's testimony about the accused talking to her brother in sign language before the incident.

During the investigation, the police found the victim's body at the crime scene and noticed blood traces on different floors of the building. They also received a phone call informing them that one of the suspects, Danilo Asis, returned to the scene. Asis was brought to the police station, where a bloodstain was noticed on his T-shirt.

The defense presented a different version of events, with Formento denying having the victim's clothes and Asis claiming he left the victim's store before Formento and returned the next day upon learning of the victim's death.

The trial court based its decision on circumstantial evidence, particularly the bloodstained pair of shorts found in Formento's bag. The defendants appealed, arguing that the prosecution's evidence was insufficient.

The prosecution relied on the principle that circumstantial evidence can lead to conviction if there is more than one circumstance, all proven facts, and a combination of circumstances that establish guilt beyond reasonable doubt. The bloodstained trousers were considered the strongest evidence against the defendants.

ISSUES:

1. Whether the circumstantial evidence presented by the prosecution is sufficient to establish the guilt of the appellants beyond reasonable doubt.

2. Whether the bloodstained pair of shorts found in the possession of one of the appellants can be considered as a strong piece of evidence against them.

3. Whether the warrantless search and seizure of the bloodstained pair of shorts was valid.

4. Whether or not the consent given by the hotel room occupant was deemed the consent of the accused.

5. Whether or not the search and seizure of the appellant's belongings were valid.

6. Whether or not the bloodstained pair of shorts and shirt are admissible as evidence.

7. Whether there was sufficient motive to establish the guilt of the appellants for the crime charged.

8. Whether the appellants being the last persons seen with the victim raised a strong suspicion of their guilt.

9. Whether the mere presence of the appellants at the crime scene was sufficient to implicate them.

10. Whether there was evidence that the appellants pointed to each other as the author of the crime.

11. Whether the elements of robbery with homicide were proved beyond reasonable doubt.

12. Whether there was adequate proof of conspiracy between the appellants.

13. Whether the RTC has jurisdiction to hear and decide the petition for habeas corpus.

14. Whether the detention of the petitioner is illegal.

RULING:

1. No, the circumstantial evidence presented by the prosecution is not sufficient to establish the guilt of the appellants beyond reasonable doubt.

2. No, the bloodstained pair of shorts found in the possession of one of the appellants cannot be considered as a strong piece of evidence against them.

3. No, the warrantless search and seizure of the bloodstained pair of shorts was not valid.

4. No, the consent given by the hotel room occupant cannot be deemed the consent of the accused. The accused, who is a deaf-mute, did not understand what was happening and there was no interpreter to assist him during the arrest, search, and seizure.

5. No, the search and seizure of the appellant's belongings were not valid. Appellant's wife, who could not understand the police officers, voluntarily surrendered the bag containing the bloodstained trousers of the victim. The surrender was not voluntary as she did not even understand the person she was communicating with.

6. The bloodstained pair of shorts and shirt are inadmissible as evidence. The seizure of the bloodstained pair of shorts was on the occasion of an unlawful search and seizure, making it tainted and the proverbial fruit of the poisonous tree. The bloodstain on appellant Asis' shirt does not prove his guilt beyond reasonable doubt as it only arouses suspicion and does not engender moral certainty.

7. The statement that the appellants got "madder and madder" at the victim was deemed too speculative to establish sufficient motive. The evidence presented by the prosecution was not enough to prove motive.

8. The fact that appellants were the last persons seen with the victim raised only speculation, but it was insufficient to establish their guilt. Mere suspicions and speculations cannot be the bases of conviction.

9. The mere presence of the appellants at the crime scene was not unusual since they had a regular connection with the victim. There was no evidence indicating that they were the only ones who had access to the crime scene, thus their presence alone did not implicate them.

10. There was no evidence that the appellants pointed to each other as the author of the crime. They did not specifically shift the blame to each other during their cross-examination and even denied doing so.

11. The prosecution failed to prove the crime of robbery as it left the crime unsubstantiated. The prosecution must prove the elements of robbery with homicide beyond reasonable doubt, but they only focused on proving the homicide.

12. There was neither proof nor finding of conspiracy between the appellants, and therefore the extent of their individual participation should have been clearly delineated. Conspiracy should be proved convincingly as the criminal act itself.

13. The RTC has jurisdiction to hear and decide the petition for habeas corpus.

14. The detention of the petitioner is illegal.

PRINCIPLES:

• Circumstantial evidence may be sufficient for conviction if there is more than one circumstance, the facts from which the inferences are derived are proven, and the combination of all the circumstances produce a conviction beyond reasonable doubt.

• The ownership of a certain item, even if found in the possession of a person, does not automatically establish that person as the doer of a wrongful act.

• The constitutional right against unreasonable searches and seizures cannot be waived by anyone except the person whose rights are invaded or who is expressly authorized to do so on his or her behalf. Consent to a search must be obtained from the person whose rights are being invaded.

• To constitute a valid waiver of constitutional rights, it must be shown that the person had knowledge of the right, an intention to relinquish the right, and the capacity to understand what is happening.

• A peaceful submission to a search or seizure is not a consent or invitation thereto, but merely a demonstration of regard for the supremacy of the law.

• Courts indulge every reasonable presumption against waiver of fundamental constitutional rights and do not presume acquiescence to the loss of fundamental rights.

• Evidence obtained through an unlawful search and seizure is considered tainted and the proverbial fruit of the poisonous tree, making it inadmissible in any proceeding.

• Mere suspicions and speculations cannot be the bases of conviction in a criminal case.

• The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.

• Circumstantial evidence that has not been adequately established or corroborated cannot be the basis of conviction.

• The constitutional right to be presumed innocent until proven guilty can only be overturned by proof beyond reasonable doubt.

• In a criminal case, the overriding consideration is whether the court entertains reasonable doubt as to the guilt of the accused.

• The RTC has jurisdiction to hear and decide the petition for habeas corpus.

• The detention of a person is illegal if it is done without legal basis.