a. Proof Beyond Reasonable Doubt

Criminal Cases -

• To Sustain Conviction – Guilt beyond reasonable doubt.
• To File an Information – probable cause - engenders a well-founded belief of the fact of the commission of a crime, and that the respondent is probably guilty thereof, and should be held for trial
• Issuance of warrant of arrest – probable cause (i.e., that there is reasonable ground to believe that a criminal offense has been committed and that the accused committed the offense).
• To deny bail when discretionary – when the evidence of guilt is strong
• To accept a plea of guilty to a capital offense – that the accused voluntarily and fully comprehended the consequences of his plea
• To grant demurrer to evidence – the evidence is insufficient to sustain a conviction

The prosecution has to prove its affirmative allegations in the information (i.e., the elements of the crime as well as the attendant circumstances); while the defense has to prove its affirmative allegations regarding the existence of justifying or exempting circumstances, absolutory causes or mitigating circumstances.

PROOF BEYOND REASONABLE DOUBT

In a criminal case, the accused is entitled to an acquittal unless his guilt is shown beyond reasonable doubt.

Proof beyond reasonable doubt does not mean such a degree of proof as excluding the possibility of error, produces absolute certainty.

Moral certainty only is required, or that degree of proof which produces conviction in an unprejudiced mind. (Rule 133 Sec. 2)

Requiring proof of guilt beyond reasonable doubt necessarily means that mere suspicion of the guilt of the accused, no matter how strong, should not sway judgment against him. It further means that the courts should duly consider every evidence favoring him; and that in the process, the courts should persistently insist that accusation is not synonymous with guilt; hence, every circumstance favoring his innocence should be fully taken into account. Without the proof of his guilt being beyond reasonable doubt, therefore, the presumption of innocence in favor of the accused herein was not overcome. (People v. Claro, G.R. No. 19994, 2017)

Circumstantial Evidence - competent to establish guilt as long as it is sufficient to establish beyond a reasonable doubt that the accused, and not someone else, was responsible for the killing.

For circumstantial evidence to suffice to convict an accused, the following requisites must concur:

• There is more than one circumstance;
• The facts from which the inferences are derived are proven; and
• The combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. In this case, these requisites for circumstantial evidence to sustain a conviction are present. (People v. Oandasan, Jr., G.R. No. 194605, 2016; Rule 133, Sec.4)

To be clear, then, circumstantial evidence may be resorted to when to insist on direct testimony would ultimately lead to setting a felon free. The Rules of Court makes no distinction between direct evidence of a fact and evidence of circumstances from which the existence of a fact may be inferred; hence, no greater degree of certainty is required when the evidence is circumstantial than when it is direct. In either case, the trier of fact must be convinced beyond a reasonable doubt of the guilt of the accused. Nor has the quantity of circumstances sufficient to convict an accused been fixed as to be reduced into some definite standard to be followed in every instance. (People v. Magbitang, G.R. No. 175592, 2016)