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PEOPLE v. ARIEL MANABAT CADENAS

FACTS:

Accused-appellants Ariel Manabat Cadenas and Gaudioso Martije were charged with Rape with Homicide. Castillo, the victim's live-in partner, testified that on the day of the incident, AAA left to prepare food while Castillo and Dindo Escribano were at the copra drier. Escribano saw Cadenas and Martije leaving their house. When they returned, they found AAA dead, naked, with her jogging pants pulled down and her vagina and breasts exposed. Dr. Guiritan testified that AAA's cause of death was brain hemorrhage due to a skull fracture. Bacus, the Chief Barangay Tanod, testified that Cadenas admitted to killing the victim. The defense claimed that Martije did not leave his house that day, while Cadenas claimed he was at home and went to the seashore to buy food. The RTC found Cadenas and Martije guilty of Rape with Homicide, affirmed by the CA with modifications to damages. Cadenas and Martije appealed, arguing insufficient evidence to prove guilt beyond reasonable doubt.

ISSUES:

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

  2. Whether the identification of the accused as the perpetrators of the crime is accurate and reliable.

  3. Whether the identification of the appellants as the perpetrators of the crime is reliable.

  4. Whether the reaction and actions of the witness are unnatural and contrary to ordinary human experience.

  5. Whether there is sufficient evidence to show motive on the part of the appellants.

RULING:

  1. The Court is not convinced with moral certainty that the accused committed the crime charged. The circumstantial evidence presented by the prosecution, particularly as to the identification of the perpetrators, is considered inadequate and insufficient to affirm their conviction. The Court finds doubt rather than moral certainty as to the guilt of the accused for the special complex crime of Rape with Homicide.

  2. The Court held that the identification of the appellants as the perpetrators is highly suspect and lacks credibility. The conditions of visibility at the time of the incident did not favor the witness, and there is no evidence to show the existence of a source of light that would have provided sufficient illumination. The positive identification of the appellants by the witness is elusive and hazy.

  3. The Court also found the reaction and actions of the witness to be unnatural and contrary to ordinary human experience. It is strange that the witness chose to return to a friend instead of entering the house where the crime allegedly took place or at least checking on the condition of the victim. The failure of the witness to provide a believable explanation leads to the conclusion that he was either withholding information or not telling the truth.

  4. Furthermore, the Court noted the lack of evidence showing motive on the part of the appellants. There was no evidence that the appellants had a grudge against the victim or her live-in partner. Motive assumes importance in this case as the evidence on the commission of the crime is purely circumstantial.

PRINCIPLES:

  • The prosecution has the burden to prove beyond reasonable doubt the fact of the crime and the identity of the perpetrator.

  • Conviction may be based on circumstantial evidence only if the following requisites concur: (a) there is more than one circumstance; (b) the facts from which the inferences are derived are proved; and (c) the combination of all the circumstances is such as to produce conviction beyond reasonable doubt.

  • Circumstantial evidence is sufficient to support a conviction if all circumstances are consistent with each other, consistent with the hypothesis of guilt, and inconsistent with the hypothesis of innocence.

  • Identification of the accused as the perpetrator of the crime must be accurate and reliable.

  • Suspicion and speculation cannot be the basis for conviction in a criminal case.

  • The presence of the accused at the crime scene does not necessarily prove their guilt.

  • Proof against the accused must pass the standard of reasonable doubt.

  • The prosecution has the burden of proving the identity of the culprits beyond reasonable doubt.

  • Inconclusive and untrustworthy identification testimony may not be used as basis for conviction.

  • The reliability of identification is crucial in determining the guilt of the accused, especially in cases where the evidence is purely circumstantial.

  • The reaction and actions of a witness should be evaluated for their credibility and consistency with ordinary human experience.

  • The prosecution has the burden of proving the guilt of the accused, and the weakness of the defense's evidence is inconsequential if the prosecution failed to prove the identity and culpability of the accused.

  • Acquittal on the ground of reasonable doubt (Philippine Jurisprudence)