ROMULO TRINIDAD @ ROMY, Petitioner,vs.PEOPLE OF THE PHILIPPINES, Respondent; G.R. No. 192241 June 13, 2012

Deceased alighted from a tricycle, confronted the bonfire attendees, shifted his focus on accused, slapped him, hit him with bamboo, chased him. He was just found dead with stab wounds. Accused was convicted thru circumstantial evidence.

Topic: Motive

CONVICTED: Romulo Trinidad

Thru: Circumstantial evidence

CRIME: Homicide

Rationale: 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

Facts: 

1. Around 9pm in October 1998, Doming boarded the tricycle of Salvador.

2. Accused, along with 5 others were having a bon fire. They flagged the tricycle of Salvador which angered Doming.

3. Doming brought out a fan knife and slapped Sonny prompting the companions of the latter, except petitioner Romulo Trinidad, to scamper. Doming approached petitioner and said, "You are one of them." Petitioner replied, "I am not x x x one [of them], uncle."

4. Thereafter, Doming slapped petitioner in the face and the latter said, "You are boastful, uncle." Doming picked up a bamboo and hit petitioner on his left arm. Petitioner ran towards the east, while Doming chased him.

5. Totoy Trinidad and Antonio Trinidad, went near the persons hiding behind the tricycle and asked them if Doming was armed, to which Sonny answered, "Yes, he has a knife." Totoy went beside Salvador and told him to put off the light of his tricycle, which the latter did not follow. Thus, Totoy turned off the engine of Salvador's tricycle and headed towards the east shortly after Doming chased petitioner to the same direction.

6. Salvador went to the house of the Barangay Captain, but the latter was asleep, prompting him to go to the police station to report that Doming was in trouble.

7. SPO4 Charlie Abuan, together with policemen Coloma and Cariaga, with Barangay Kagawad Rudy Sabado and Salvador, went to the scene of the crime and saw the bloodied body of the victim in a kneeling position with his forehead touching the ground. Five (5) persons were brought to the police station for investigation.

8. RTC acquitted Totoy Trinidad, Petitioner's father on reasonable doubt and convicted Antonio and petitioner.

9. It was appealed to CA. CA acquitted Antonio Trinidad on reasonable doubt, but affirmed the conviction of petitioner.

10. Petitioner insists that the prosecution was not able to prove his guilt beyond reasonable doubt because the circumstantial evidence presented during the trial is insufficient. According to him, he was not the only person who had a motive to kill the victim; thus, the presumption of innocence should be in his favor.

Issue:

W/N Romulo be acquitted on the ground that he is not is only person with motive to kill the victim.

Ruling: 

NO. He is convicted of homicide.

The settled rule is that a judgment of conviction based purely on circumstantial evidence can be upheld only if the following requisites concur:

(1) there is more than one circumstance;

(2) the facts from which the inferences are derived are proven; and 

(3) the combination of all the circumstances is such as to produce conviction beyond reasonable doubt. 

The corollary rule is that the circumstances proven must constitute an unbroken chain which leads to one fair and reasonable conclusion pointing to the accused, to the exclusion of all others, as the guilty person, i.e., the circumstances proven must be consistent with each other, consistent with the hypothesis that the accused is guilty and at the same time inconsistent with the hypothesis that he is innocent and with any other rational hypothesis except that of guilt.

Indeed, motive becomes material when the e evidence is circumstantial or inconclusive, and there is some doubt on whether a crime has been committed or whether the accused has committed it. The following circumstantial evidence is sufficient to convict accused:

1. Accused had motive to kill the deceased because during the altercation the latter slapped and hit him with a bamboo, prompting Romulo to get mad at the deceased;

 2. Accused was chased by the deceased eastward after the slapping and hitting incident; 

3. Said accused was the last person seen with the deceased just before he died;

4. Accused and Antonio Trinidad surrendered to police authorities with the samurai; Accused Antonio was seen holding a "Samurai" just when he and Romulo decided to surrender the same night of the accident;

5. The deceased sustained multiple stab/hacking wounds and contusions probably caused by two or three or more assailants using a knife or a bolo or even a stone;

6.  Romulo and Antonio surrendered to the authorities the following morning before a warrant could be issued for their arrest;

7. The prosecution witnesses, Salvador Oaña, Eliseo Agno and Rodolfo Sabado, Jr. had no ill motive to testify against the accused.

The series of circumstances proven during the trial form an unbroken chain of events leading to the conclusion that petitioner was one of the assailants.