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People vs. Anticamara G.R. No. 178771 June 8, 2011 Peralta, J

The Supreme Court upheld the conviction of several individuals for kidnapping and murder based on circumstantial evidence alone. While there were no eyewitnesses to the actual killing, the prosecution established that: (1) the defendants entered the victim's employer's house, tied up the victim and housemaid, and drove them to a fishpond; (2) the housemaid heard discussion of shooting the victim four times; and (3) the defendant later admitted to participating and led authorities to the victim's shallow grave, where autopsy showed cause of death was gunshot wounds. The Court found this circumstantial evidence sufficiently proved the defendants' guilt beyond a reasonable doubt.

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173 views3 pages

People vs. Anticamara G.R. No. 178771 June 8, 2011 Peralta, J

The Supreme Court upheld the conviction of several individuals for kidnapping and murder based on circumstantial evidence alone. While there were no eyewitnesses to the actual killing, the prosecution established that: (1) the defendants entered the victim's employer's house, tied up the victim and housemaid, and drove them to a fishpond; (2) the housemaid heard discussion of shooting the victim four times; and (3) the defendant later admitted to participating and led authorities to the victim's shallow grave, where autopsy showed cause of death was gunshot wounds. The Court found this circumstantial evidence sufficiently proved the defendants' guilt beyond a reasonable doubt.

Uploaded by

Harvey Leo Romano
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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PEOPLE VS.

ANTICAMARA
G.R. No. 178771
June 8, 2011
Peralta, J:

Circumstantial evidence consists of proof of collateral facts and circumstances from which the
existence of the main fact may be inferred according to reason and common experience .9
Circumstantial evidence is sufficient to sustain conviction if: (a) there is more than one
circumstance; (b) the facts from which the inferences are derived are proven; (c) the combination
of all circumstances is such as to produce a conviction beyond reasonable doubt.10 A judgment of
conviction based on circumstantial evidence can be sustained when the circumstances proved form
an unbroken chain that results in a fair and reasonable conclusion pointing to the accused, to the
exclusion of all others, as the perpetrator.

Facts: Conrado Estrella and his wife employed AAA and Sulpacio Abad as maid and driver
respectively. Sometime on the afternoon of 07 May 2002, the group of Fernando Fernandez
(Lando), Alberto Anticamara (Al), Dick Taedo (Dick), Roberto Taedo (Bet), Marvin Lim (Marvin),
and Fred Doe entered the house of AAA’s employer whilst she was sleeping. Thinking that the
intruders left the house already, she attempted to run but Dick was still there. After a brief
commotion, the group decided to tie AAA and was led outside the house. AAA saw Abad tied and
blindfolded inside a vehicle.

AAA was brought to the fishpond, there she saw Necitas Ordeiza-Taedo (Cita). The group brought
Abad outside the vehicle and was led away. AAA heard the group discussing to make a decision
since Abad apparently has been shot four times. Later on, Lando and Fred boarded the vehicle
taking AAA with them to San Miguel, Tarlac. She was kept in Lando’s house until 09 May 2002.

On 09 May 2002, Lando told AAA that Fred and Bert has intention to kill her and he brought her to a
hotel. Through threat, Lando sexually molested AAA. Later on Fred, Bert and Lando transferred
AAA to the house of Fred’s niece in Riles, Tarlac. Fred kept AAA as a wife and repeatedly raped her
at night, threatening to give her back to Lando whom she knew killed Abad.

On 22 May 2002, Fred, together with his family, transferred AAA to Carnaga. AAA was made to stay
as a house helper in the house of Fred’s brother-in-law. On 04 June 2002, AAA escaped the house
and sought help from her friend who called AAA’s brother. Arriving Mandaue City, AAA and her
brother reported the incident to police authorities. The cadaver of Abad was autopsied and cause of
death was gunshot wounds on trunk.

ISSUE: Wheter or not the accused can be found guilty based on circumstantial evidence alone.

HELD: The cort ruled in the affirmative. The trial court found that although there was no direct
eyewitness in the killing of Sulpacio in the early morning of May 7, 2002 at Sitio Rosalia, Barangay
San Bartolome, Rosales, Pangasinan, the prosecution adduced sufficient circumstantial evidence to
establish with moral certainty the identities and guilt of the perpetrators of the crime.

Circumstantial evidence consists of proof of collateral facts and circumstances from which the
existence of the main fact may be inferred according to reason and common experience .9
Circumstantial evidence is sufficient to sustain conviction if: (a) there is more than one
circumstance; (b) the facts from which the inferences are derived are proven; (c) the combination
of all circumstances is such as to produce a conviction beyond reasonable doubt.10 A judgment of
conviction based on circumstantial evidence can be sustained when the circumstances proved form
an unbroken chain that results in a fair and reasonable conclusion pointing to the accused, to the
exclusion of all others, as the perpetrator.

In this case, the circumstantial evidence presented by the prosecution, when analyzed and taken
together, lead to the inescapable conclusion that the appellants are responsible for the death of
Sulpacio. The Court quotes with approval the lower court's enumeration of those circumstantial
evidence:

The testimony of AAA had clearly established the following facts:

1. At about 3:00 in the early morning of May 7, 2002, while she and the victim Abad Sulpacio were
sleeping inside the house of the Estrella family in Barangay Carmen, Rosales, Pangasinan several
persons entered to rob the place;

2. Inside the house, she saw and recognized the accused Lando Calaguas and Dick Tañ edo, and
heard the latter uttering "somebody will die";

3. Bringing her outside the house, Lando pushed her into the Revo where she saw inside Abad
Sulpacio who was blindfolded and with his hands tied;

4. Inside the Revo, she recognized the accused Dick Tañ edo, Lando Calaguas, Marvin Lim, Roberto
Tañ edo, Alberto Anticamara and Fred;

5. The Revo then proceeded towards the fishpond owned by the Estrellas in Sitio Rosalia, Brgy. San
Bartolome, Rosales, Pangasinan;

6. The last time that she saw Abad Sulpacio was when he was dragged out from the vehicle by
Lando, Fred, Marvin and Al upon reaching Sitio Rosalia. At that, time Dick Tañ edo stayed with her in
the vehicle;

7. Thereafter, when Fred returned to the vehicle, she heard him uttered (sic): "Make a decision now.
Abad has already four (4) bullets in his body, and the one left is for this girl."12

In addition to these circumstances, the trial court further found that AAA heard Fred utter "Usapan
natin pare, kung sino ang masagasaan, sagasaan." (Our agreement is that whoever comes our way
should be eliminated). Moreover, NBI Agent Gerald V. Geralde testified that on June 23, 2002,
appellant Al admitted his participation as lookout and naming his companions Dick, Lando, Fred,
Marvin and Bet as the ones who took AAA and Sulpacio from the house of the Estrellas and brought
them to the fishpond. Al also pointed and led the authorities to a shallow grave in Sitio Rosalia,
Barangay San Bartolome, Rosales, Pangasinan, where the remains of Sulpacio were buried. The
autopsy conducted on the body, prepared by the Medico Legal Officer Dr. Bandonil, shows that
several holes were found on various parts of the body of the victim and Dr. Bandonil concluded that
the cause of the victim's death was the gunshot wounds. The report also indicates that a piece of
cloth was found wrapped around the eye sockets and tied at the back of the skull, and another cloth
was also found tied at the remnants of the left wrist.

In the case at bar, although no one directly saw the actual killing of Sulpacio, the prosecution was
able to paint a clear picture that the appellants took Sulpacio away from the house of the Estrellas,
tied and blindfolded him, and brought him to another place where he was repeatedly shot and
buried.

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