PEOPLE OF THE PHILIPPINES, vs. ALEX RAMOS alias "BULKO" (at large), accused,
- G.R. Number: G.R. No. 104497
- Promulgated: 1995-01-18
- Ponente: Puno, J.
Doctrine
Circumstantial evidence, when strong and excluding every hypothesis except guilt, can overturn the presumption of innocence and sustain conviction.
Nighttime is an aggravating circumstance when it was deliberately and purposely sought to facilitate the commission of the crime.
Circumstances such as dwelling and abuse of superior strength (vulnerable victims, multiple wounds) may be appreciated as aggravating.
Facts
Appellants Angel Fernandez, Marco Fernandez, Rodolfo Tulagan and Alex Ramos (alias “Bulko”) were charged in an Information dated 24 November 1987 with robbery with homicide for an incident on the evening of 26 October 1987 at Barangay West Poblacion, Rizal, Laguna.
The Regional Trial Court convicted three appellants (Angel, Marco, Rodolfo) of Robbery with Homicide and sentenced each to reclusion perpetua; civil indemnities and awards for funeral expenses and loss of earnings were ordered.
On appeal the critical issue raised was whether the prosecution’s circumstantial evidence was sufficient to support conviction and whether conspiracy was proved.
Issues
Whether the circumstantial evidence adduced by the prosecution is sufficient to support the judgment of conviction against appellants.
Whether conspiracy among the accused was established.
Ruling
The Court affirmed the judgment of conviction; it held the circumstantial evidence sufficiently inculpated appellants and removed reasonable doubt, overturning the presumption of innocence.
The Court recognized attendant aggravating circumstances (nighttime sought to facilitate the crime, use of craft to gain entry, dwelling, abuse of superior strength) and increased the civil indemnity to P50,000.00; costs against appellants.