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Robbery with Homicide Case Analysis

The Supreme Court of the Philippines ruled that the trial court erred in finding the accused guilty of robbery with homicide based on circumstantial evidence alone. Circumstantial evidence must do more than raise suspicions or possibilities of guilt - it must create moral certainty of guilt. Here, there were no eyewitnesses and none of the allegedly stolen items were recovered from the accused. The bloodstained clothing of the accused created suspicion but not moral certainty that they committed the crime. Therefore, the constitutional presumption of innocence prevailed and the accused deserved acquittal.

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248 views1 page

Robbery with Homicide Case Analysis

The Supreme Court of the Philippines ruled that the trial court erred in finding the accused guilty of robbery with homicide based on circumstantial evidence alone. Circumstantial evidence must do more than raise suspicions or possibilities of guilt - it must create moral certainty of guilt. Here, there were no eyewitnesses and none of the allegedly stolen items were recovered from the accused. The bloodstained clothing of the accused created suspicion but not moral certainty that they committed the crime. Therefore, the constitutional presumption of innocence prevailed and the accused deserved acquittal.

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MAC
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© © All Rights Reserved
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  • Court Case Analysis: Analyzes the issue of the court's decision regarding the accused-appellants' guilt beyond reasonable doubt in a particular case.

People vs.

Asis
G.R. No. 142531 October 15, 2002

Issue: Whether or not the trial court gravely erred in finding the accused-appellants guilty beyond
reasonable doubt of the crime of robbery with homicide notwithstanding the insufficiency of the
circumstantial evidence presented by the prosecution.

Held: Yes.

Circumstantial evidence that merely arouses suspicions or gives room for conjecture is not sufficient to
convict. It must do more than just raise the possibility, or even the probability, of guilt. It must engender
moral certainty. Otherwise, the constitutional presumption of innocence prevails, and the accused
deserves acquittal.

It must be stressed that in our criminal justice system, the overriding consideration is not whether the court
doubts the innocence of the accused, but whether it entertains a reasonable doubt as to their guilt. Where
there is no moral certainty as to their guilt, they must be acquitted even though their innocence may be
questionable. The constitutional right to be presumed innocent until proven guilty can be overthrown only
by proof beyond reasonable doubt.

Here, two things stand out: first, there were no eyewitnesses to the robbery or to the homicide; and
second, none of the items allegedly stolen were recovered or presented in evidence. How the recovery of
a bloodstained pair of shorts allegedly owned by the victim should give rise to the presumption that one of
the appellants was the taker and doer of the whole act of robbery with homicide. And even granting for the
sake of argument that it indeed belonged to the victim, still, there is no evidence to prove that it was taken
from him on the night of the homicide. Neither can it be ruled out that he might have lent it or gave it to
either one of the two.

The prosecution then contends that when the other appellant, Danilo Asis, was brought to the police
station for investigation the following day, the police found bloodstain on his shirt. Again, this fact cannot
be taken as an indication of guilt on the part of Appellant Asis. It does not point to the conclusion that he
was involved in the crime charged against him. The Court cannot agree that since there was bloodstain on
his clothing, ergo, he committed the robbery and the attendant killing. At most, this piece of circumstantial
evidence, taken with the other one, may lead to suspicion.

In the final analysis, the circumstances narrated by the prosecution engender doubt rather than moral
certainty on the guilt of appellants.

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