Lawyerly

GR No. 213913

2015-09-02

PEOPLE v. JULKIPLI ASAMUDDIN Y SALAPUDIN A.K.A.'JUL'

VILLARAMA, JR., J.

In the face of the overwhelming and positive evidence against the appellant, even if his return to Zamboanga City is disregarded as an indication of his guilty conscience, his conviction should still be sustained. Unfortunately for appellant, there is no case law holding non-flight as an indication or as conclusive proof of innocence.[60]

GR No. 214883

2015-09-02

PEOPLE v. CRISTINA SAMSON

MENDOZA, J.

Generally, flight, in the absence of a credible explanation, would be a circumstance from which an inference of guilt might be established, for a truly innocent person would normally grasp the first available opportunity to defend himself and assert his innocence.[29] It has been held, however, that non-flight may not be construed as an indication of innocence either. There is no law or dictum holding that staying put is proof of innocence, for the Court is not blind to the cunning ways of a wolf which, after a kill, may feign innocence and choose not to flee.[30] In Cristina's case, she explained that she took flight for fear of her safety because of possible retaliation from her husband's siblings.[31] The Court finds such reason for her choice to flee acceptable. She did not hide from the law but from those who would possibly do her harm.

GR No. 183202

2014-06-02

ALBERTO ALMOJUELA Y VILLANUEVA v. PEOPLE

BRION, J.

Sixth, Almojuela hid in the kamoteng kahoy thicket near his house when policemen visited him for investigation. We have repeatedly held that flight is an indication of guilt. The flight of an accused, in the absence of a credible explanation, is a circumstance from which guilt may be inferred. An innocent person will normally grasp the first available opportunity to defend himself and assert his innocence.[28]

GR No. 172896

2010-04-19

ROÑO SEGURITAN Y JARA v. PEOPLE

DEL CASTILLO, J.

As regards the amount of damages, civil indemnity must also be awarded to the heirs of Lucrecio without need of proof other than the fact that a crime was committed resulting in the death of the victim and that petitioner was responsible therefor.[25] Accordingly, we award the sum of P50,000.00 in line with current jurisprudence.[26]

GR No. 173510

2010-03-15

ERPASCUAL DIEGA Y PAJARES v. CA

DEL CASTILLO, J.

Conversely, the evil motive imputed to the aunt of "AAA" due to a land dispute between the appellant's employer and the parents of "AAA" deserves scant consideration. The charge of revenge and resentment is nothing more than unmitigated speculation as not a shred of evidence was offered in support thereof. While there was evidence of an existing land dispute between the family of the victim and the employer of the appellant, there was no proof to substantiate the allegation that the said hostility motivated the aunt of "AAA" to testify falsely against him. Besides, the land dispute was between the plantation owner and the family of "AAA" and not between the latter and the appellant. In the absence of evidence that the prosecution witnesses were actuated by improper motive, the presumption is that they were not so actuated and that their testimonies are entitled to credence.[23]

GR NO. 165884

2007-04-23

CIELITO R. GAN v. PEOPLE

CHICO-NAZARIO, J.

Finally, petitioner's argument that the fact that he was arrested in Parañaque does not mean he fled because he had no knowledge that there were warrants for his arrest does not hold water. It must be stressed that petitioner, after learning that he was the one being pointed to as the culprit during the conduct of the external audit, suddenly resigned and left the school without securing any clearance. He was apprehended only after more than two years of searching. Jurisprudence has repeatedly declared that flight is an indication of guilt. The flight of an accused, in the absence of a credible explanation, would be a circumstance from which an inference of guilt may be established 'for a truly innocent person would normally grasp the first available opportunity to defend himself and to assert his innocence.'[73] Under the circumstances, it is clear that petitioner tried to evade responsibility for the money that he took. Knowing fully well that he is the suspect, he suddenly disappeared without any clearance from the school. He did not even try to clear his name considering that the external audit was already on-going when he fled. Such actuation clearly indicates he is guilty. It does not matter if he does not know about the warrants for his arrest because his purpose is precisely to avoid liability for his actions. The explanation proffered by petitioner that he resigned because of the pressure coming from Dantes, Manio and Sarmenta who pointed to him as the culprit, is flimsy and does not deserve any consideration.

GR NO. 166479

2006-02-28

RODOLFO C. VELASCO v. PEOPLE

CHICO-NAZARIO, J.

Petitioner's asseveration that it is unthinkable for him to shoot private complainant because he has no motive to harm, much less kill the latter, he being a total stranger, deserves scant consideration. It must be stressed that motive is a state of (one's) mind which others cannot discern. It is not an element of the crime, and as such does not have to be proved. In fact, lack of motive for committing a crime does not preclude conviction. It is judicial knowledge that persons have been killed or assaulted for no reason at all.[39] Even in the absence of a known motive, the time-honored rule is that motive is not essential to convict when there is no doubt as to the identity of the culprit.[40] Motive assumes significance only where there is no showing of who the perpetrator of the crime was.[41] In the case at bar, since petitioner has been positively identified as the assailant, the lack of motive is no longer of consequence.

GR No. 152176

2003-10-01

PEOPLE v. ROGER DELA CRUZ Y DOE

YNARES-SANTIAGO, J.

Basic is the rule that the findings of the trial court on the credibility of witnesses and their testimonies are entitled to the highest respect and will not be disturbed on appeal, in the absence of any clear showing that it overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which would have affected the result of the case.[9] None of the aforesaid exceptions obtains in the case at bar.

GR No. 152221

2003-08-25

PEOPLE v. JACINTO ALVAREZ

YNARES-SANTIAGO, J.

We agree with the trial court in its award of P50,000.00 as civil indemnity. The victim's heirs are entitled to civil indemnity in the said amount without proof other than the fact of the victim's death.[15]

GR No. 143294

2003-07-17

PEOPLE v. CIRILO MAGALONA Y ONOON

PER CURIAM

The trial court convicted appellant based on circumstantial evidence. Direct evidence of the commission of the crime is not indispensable for convicting an accused when circumstantial evidence can sufficiently establish his guilt.[56] There can be a judgment of conviction when the circumstances proved constitute an unbroken chain of events that leads to a fair and reasonable conclusion pinpointing the accused, to the exclusion of all others, as the perpetrator of the crime.[57] Under Rule 133, Section 4 of the Rules of Court, circumstantial evidence is sufficient for conviction if: (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 a conviction beyond reasonable doubt.

	GR No. 213913 2015-09-02	PEOPLE v. JULKIPLI ASAMUDDIN Y SALAPUDIN A.K.A.'JUL' VILLARAMA, JR., J.
In the face of the overwhelming and positive evidence against the appellant, even if his return to Zamboanga City is disregarded as an indication of his guilty conscience, his conviction should still be sustained. Unfortunately for appellant, there is no case law holding non-flight as an indication or as conclusive proof of innocence.[60]
	GR No. 214883 2015-09-02	PEOPLE v. CRISTINA SAMSON MENDOZA, J.
Generally, flight, in the absence of a credible explanation, would be a circumstance from which an inference of guilt might be established, for a truly innocent person would normally grasp the first available opportunity to defend himself and assert his innocence.[29] It has been held, however, that non-flight may not be construed as an indication of innocence either. There is no law or dictum holding that staying put is proof of innocence, for the Court is not blind to the cunning ways of a wolf which, after a kill, may feign innocence and choose not to flee.[30] In Cristina's case, she explained that she took flight for fear of her safety because of possible retaliation from her husband's siblings.[31] The Court finds such reason for her choice to flee acceptable. She did not hide from the law but from those who would possibly do her harm.
	GR No. 183202 2014-06-02	ALBERTO ALMOJUELA Y VILLANUEVA v. PEOPLE BRION, J.
Sixth, Almojuela hid in the kamoteng kahoy thicket near his house when policemen visited him for investigation. We have repeatedly held that flight is an indication of guilt. The flight of an accused, in the absence of a credible explanation, is a circumstance from which guilt may be inferred. An innocent person will normally grasp the first available opportunity to defend himself and assert his innocence.[28]
	GR No. 172896 2010-04-19	ROÑO SEGURITAN Y JARA v. PEOPLE DEL CASTILLO, J.
As regards the amount of damages, civil indemnity must also be awarded to the heirs of Lucrecio without need of proof other than the fact that a crime was committed resulting in the death of the victim and that petitioner was responsible therefor.[25] Accordingly, we award the sum of P50,000.00 in line with current jurisprudence.[26]
	GR No. 173510 2010-03-15	ERPASCUAL DIEGA Y PAJARES v. CA DEL CASTILLO, J.
Conversely, the evil motive imputed to the aunt of "AAA" due to a land dispute between the appellant's employer and the parents of "AAA" deserves scant consideration. The charge of revenge and resentment is nothing more than unmitigated speculation as not a shred of evidence was offered in support thereof. While there was evidence of an existing land dispute between the family of the victim and the employer of the appellant, there was no proof to substantiate the allegation that the said hostility motivated the aunt of "AAA" to testify falsely against him. Besides, the land dispute was between the plantation owner and the family of "AAA" and not between the latter and the appellant. In the absence of evidence that the prosecution witnesses were actuated by improper motive, the presumption is that they were not so actuated and that their testimonies are entitled to credence.[23]
	GR NO. 165884 2007-04-23	CIELITO R. GAN v. PEOPLE CHICO-NAZARIO, J.
Finally, petitioner's argument that the fact that he was arrested in Parañaque does not mean he fled because he had no knowledge that there were warrants for his arrest does not hold water. It must be stressed that petitioner, after learning that he was the one being pointed to as the culprit during the conduct of the external audit, suddenly resigned and left the school without securing any clearance. He was apprehended only after more than two years of searching. Jurisprudence has repeatedly declared that flight is an indication of guilt. The flight of an accused, in the absence of a credible explanation, would be a circumstance from which an inference of guilt may be established 'for a truly innocent person would normally grasp the first available opportunity to defend himself and to assert his innocence.'[73] Under the circumstances, it is clear that petitioner tried to evade responsibility for the money that he took. Knowing fully well that he is the suspect, he suddenly disappeared without any clearance from the school. He did not even try to clear his name considering that the external audit was already on-going when he fled. Such actuation clearly indicates he is guilty. It does not matter if he does not know about the warrants for his arrest because his purpose is precisely to avoid liability for his actions. The explanation proffered by petitioner that he resigned because of the pressure coming from Dantes, Manio and Sarmenta who pointed to him as the culprit, is flimsy and does not deserve any consideration.
	GR NO. 166479 2006-02-28	RODOLFO C. VELASCO v. PEOPLE CHICO-NAZARIO, J.
Petitioner's asseveration that it is unthinkable for him to shoot private complainant because he has no motive to harm, much less kill the latter, he being a total stranger, deserves scant consideration. It must be stressed that motive is a state of (one's) mind which others cannot discern. It is not an element of the crime, and as such does not have to be proved. In fact, lack of motive for committing a crime does not preclude conviction. It is judicial knowledge that persons have been killed or assaulted for no reason at all.[39] Even in the absence of a known motive, the time-honored rule is that motive is not essential to convict when there is no doubt as to the identity of the culprit.[40] Motive assumes significance only where there is no showing of who the perpetrator of the crime was.[41] In the case at bar, since petitioner has been positively identified as the assailant, the lack of motive is no longer of consequence.
	GR No. 152176 2003-10-01	PEOPLE v. ROGER DELA CRUZ Y DOE YNARES-SANTIAGO, J.
Basic is the rule that the findings of the trial court on the credibility of witnesses and their testimonies are entitled to the highest respect and will not be disturbed on appeal, in the absence of any clear showing that it overlooked, misunderstood or misapplied some facts or circumstances of weight and substance which would have affected the result of the case.[9] None of the aforesaid exceptions obtains in the case at bar.
	GR No. 152221 2003-08-25	PEOPLE v. JACINTO ALVAREZ YNARES-SANTIAGO, J.
We agree with the trial court in its award of P50,000.00 as civil indemnity. The victim's heirs are entitled to civil indemnity in the said amount without proof other than the fact of the victim's death.[15]
	GR No. 143294 2003-07-17	PEOPLE v. CIRILO MAGALONA Y ONOON PER CURIAM
The trial court convicted appellant based on circumstantial evidence. Direct evidence of the commission of the crime is not indispensable for convicting an accused when circumstantial evidence can sufficiently establish his guilt.[56] There can be a judgment of conviction when the circumstances proved constitute an unbroken chain of events that leads to a fair and reasonable conclusion pinpointing the accused, to the exclusion of all others, as the perpetrator of the crime.[57] Under Rule 133, Section 4 of the Rules of Court, circumstantial evidence is sufficient for conviction if: (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 a conviction beyond reasonable doubt.

PEOPLE v. JONATHAN DIAZ