G.R. No.

210760, January 26, 2015, KYLE ANTHONY ZABALA,

PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
Facts:
Randolph filed a case for theft against Kyle. He was supported in the case by
Marlyn Pinon, who testified that in the early morning of June 18, 2007, she and
Kyle were at Kyles house a mere six to seven steps from Randolphs house. She
then saw him climb the fence and enter Randolphs house. When he came out,
his pockets were bulging with money. At 10:00 in the morning, she and Kyle went
to Greenhills to buy some cellphones.
After trial, the RTC convicted Kyle as charged. On appeal to the CA, the latter affirmed
the conviction, holding that there was enough circumstantial evidence to convict Kyle
for theft.
ISSUE:
Whether or not circumstantial evidence in the case warrants the conviction of Kyle for
theft.
RULING:
The SC reversed the findings of the RTC and the CA.
To sustain a conviction based on circumstantial evidence, it is essential that the
circumstantial evidence presented must constitute an unbroken chain which leads one
to a fair and reasonable conclusion pointing to the accused, to the exclusion of the
others, as the guilty person. The circumstantial evidence must exclude the possibility
that some other person has committed the crime.
Unfortunately, in the case at bar, this Court finds that the prosecution failed to present
sufficient circumstantial evidence to convict the petitioner of the offense charged. We
find that the pieces of evidence presented before the trial court fail to provide a
sufficient combination of circumstances, as to produce a conviction beyond reasonable
doubt.

FIRST DIVISION, G.R. No. 182794, September 08, 2014, PEOPLE OF THE PHILIPPINES,
PLAINTIFF-APPELLEE, VS. BOBBY BELGAR, ACCUSED-APPELLANT.
Facts:
AAA was sleeping inside their house in Tigaon, Camarines Sur on January 20, 2000 at
around 8:00 PM when she was awakened by someone touching her feet, whom she
saw as accused Bobby Belgar. He then poked a knife at her neck, dragged her outside
the house, brought her to a nearby tree and injected an unknown substance into her
stomach. She fell unconscious; when she woke up she found herself naked, her vagina
aching and soaked with white and red substance.
The RTC convicted him as charged and did not believe his defense of alibi as against
the candid and truthful narration of AAA of the incident. The Court of Appeals affirmed
the RTC judgment, holding that the conviction for rape could be based on the
circumstantial evidence adduced through the testimony of AAA.
Issue:
Whether or not accused may be convicted for rape based on circumstantial evidence.
Ruling:
The commission of the rape was competently established although AAA had been
unconscious during the commission of the act. Proof of the commission of the crime
need not always be by direct evidence, for circumstantial evidence could also
sufficiently and competently establish the crime beyond reasonable doubt. Indeed, the
Court affirmed convictions for rape based on circumstantial evidence. 10 In this
connection, circumstantial evidence is sufficient for conviction if the conditions set
forth in Section 4, Rule 133 of the Rules of Court are shown to exist, to wit:
Section 4. Circumstantial evidence, when sufficient. Circumstantial evidence is
sufficient for conviction if:
(a) There is more than one circumstance;
(b) The facts from which the inferences are derived are proven; and
(c) The combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.

FIRST DIVISION, G.R. No. 209386, December 08, 2014, MEL

CARPIZO CANDELARIA, PETITIONER, VS. THE PEOPLE OF THE
PHILIPPINES, RESPONDENT.

Facts:
The Regional Trial Court convicted Candelaria of Qualified Theft, relying on
circumstantial evidence such as: Mel was the driver of the truck containing diesel fuel
bound for delivery to Viron; Viron did not receive the fuel; and the truck was
discovered without its contents. Mel appealed his conviction to the CA. The latter,
however, affirmed his conviction. Mel appealed his case to the Supreme Court,
reiterating his contentions in his demurrer to evidence that no direct evidence linked
hot to the crime, and Romanos information was hearsay.
Issue:
Whether or not circumstantial evidence is sufficient to convict the accused of
qualified theft.

Ruling:

Circumstantial evidence is sufficient for conviction if: (a) there is more than one
circumstance; (b) the facts from which the inferences are derived are proven; and (c)
the combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.[5] Circumstantial evidence suffices to convict an accused only if the
circumstances proven constitute an unbroken chain which leads to one fair and
reasonable conclusion pointing to the accused, to the exclusion of all others, as the
guilty person; the circumstances proved must be consistent with each other, consistent
with the hypothesis that the accused is guilty, and, at the same time, inconsistent with
any other hypothesis except that of guilt. Corollary thereto, a conviction based on

circumstantial evidence must exclude each and every hypothesis consistent with
innocence.