Myline Cordial

People of the Philippines vs. Bonifacio Baltazar
G.R. No. 129380, October 19, 2000
343 SCRA 685

FACTS:
Bonifacio Baltazar reported to the Barangay Captain that there was a foul odor coming from one of the tombs in the cemetery. Acting on the report, the Tanods found a decomposing body of a girl who had been missing.

Two years later, Baltazar was charged with murder for killing the victim. During the trial, the prosecution presented a witness who testified that he passed by the victim and the accused walking towards the cemetery in the afternoon immediately before the disappearance of the victim. Another testified that the accused did not attend the burial of the victim.

Based on this circumstantial evidence, the trial court convicted the accused of murder.

ISSUE:
Was the conviction based on circumstantial evidence proper?

RULING:
No. The prosecution presented in evidence only one circumstance indirectly linking the accused to the crime. For a conviction based on circumstantial evidence to prosper, the prosecution must establish more than one circumstance indubitably linking the accused to the commission of the crime. Likewise, the facts from which the inferences are derived are proved and that the combination of all these circumstances must produce a conviction beyond reasonable doubt.
For a conviction based on circumstantial evidence to stand, it is imperative that there be a confluence of circumstances. These circumstances which are proved must 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. In this case, the web of circumstances adverted does not constitute an unbroken chain that would fairly lead to the conclusion that it was accused-appellant who killed the victim.

Full text: People of the Philippines vs. Baltazar G.R. No. 129380 (2000)