People vs.

Salas
Rule 116. Sec.1(B) During Trial for Identification
The case:
This is an appeal for judgment of the decision of the RTC of Pampanga for finding the appellant, Elmer
Salas guilty of robbery with homicide and imposing upon him the penalty of reclusion perpetua.
Facts:
On March of 1992 at 6am, after visiting a wake, one Virginia Talens, 60-year old of age, was
found dead at a canal at San Nicolas, Pampanga with different stab wounds on her body. The
Information filed by the Office of Provincial Prosecutor accusing the appellant of stabbing the
victim with a bladed weapon, causing her death and the stealing of the victims money of P2000
and a piece of gold earring valued at P750.
The RTC found Salas guilty beyond reasonable doubt for Robbery with Homicide sentencing him
to reclusion perpetua and the reimbursement of the P2000 amount and the civil indemnity of
P50,000 to the victims heirs.
Salas appealed and stated that the RTC erred in convicting him of the said crime based only on
the chain of events and circumstantial evidence presented by the state , and the scanty
evidence of the witnesses that he was the last person seen in the company of the victim during
the early morning of her death.
Issue: WON there is evidence sufficient to sustain a conviction of the appellant of the crime of Robbery
with Homicide.
Held: Yes.
Rationale:
Although there were no direct evidence to either of the robbery and homicide, previous
jurisprudence (People v. Lopez and People vs. De la Cruz) ruled that , direct evidence is not the
only matrix from which the trial court may draw its findings and conclusion of
culpability.
8
Resort to circumstantial evidence is essential when to insist on direct testimony
would result in setting felons free
Sec. 4, Rule 133 of the Rules of Court and PP vs. Olivarez state that For circumstantial evidence
to be sufficient to support a conviction, all the circumstances must be consistent with each
other, consistent with the theory that the accused is guilty of the offense charged, and at the
same time inconsistent with the hypothesis that he is innocent and with every other possible,
rational hypothesis excepting that of guilt.
The circumstances of the accused abandoning his house at the same day of the death of the
victim and his sudden quitting of his job, including the bloodstains found of his house, lead to
the crimes filed.
The appellant denies such allegations but according to PP vs. Macuha and PP vs. Mores state
that Denial is an inherently weak defense which must be buttressed by strong evidence of
non-culpability to merit credibility. Denial is negative and self-serving and cannot be given
greater evidentiary weight over the testimonies of credible witnesses who positively testified
that appellant was at the locus criminis and was the last person seen with the victim alive
Spontaneity and an intent to give one's self up are absent where the accused went into hiding
for six months after the incident and had to resort to an alias name during his
hospitalization when he was involved in an accident being investigated by the police authorities.
While there is indeed no direct proof that Virginia Talens was robbed at the time she was killed,
we may conclude from four circumstances that the robbery occasioned her killing: (1) Both
appellant and victim gambled at the wake. (2) The appellant knew that victim was winning. (3)
The victim was last seen alive with appellant. (4) The victim's purse containing her money and
earrings were missing from her body when found.
WHEREFORE, the decision of the RTC is affirmed.