Manulat vs. People, G.R. No.

190892, August 17, 2015

Facts: The crime of parricide was filed against Vicente Manulat for allegedly killing
his wife. The RTC and the CA found the accused guilty. Accused contends that there
was no sufficient evidence that would establish his guilt beyond reasonable doubt.
Hence, this petition for review on certiorari to the SC.
On the afternoon of Sept. 04, 2005, the neighbor of the spouses Vicente and
Genebe Manulat heard the spouses quarelling, even hearing the accused saying
Day, If I get hurt I would box you. Additionally, she said she even heard sounds of
breaking ceramics and a thud before there was silence.
In the evening of the same day, petitioner brought their children to the house of his
mother-in-law and confessed that they had a fight with his wife and that he couldve
killed her if their children were hit as a consequence of the fight.
On the next morning, as the mother-in-law was bathing the two children, the latter
confided to her that their mother was killed by their father. On the afternoon of the
same day, their neighbor rushed into the house of the spouses upon hearing the
petitioner shouting for help. They found the dead body of the victim hanging on a
rope above her bed. Police officers went to the crime scene and noticed that the
house was a mess. One offficer also noticed that the noose of the rope allegedly
used by the victim to commit suicide could not be tightened.
Issue: Whether accused is guilty of parricide?
Ruling: Petitioner is guilty of parricide. The court relied solely on the circumstantial
evidence presented by the prosecution. The court ruled that the lack or absence of
direct evidence does not necessarily mean that the guilt of the accused cannot be
proven by evidence other than direct evidence. Circumstantial evidence, if
sufficient, can supplant the absence of direct evidence.
The series of circumstances duly proved must be consistent with each other and
must likewise be consistent with the accused's guilt and inconsistent with his
innocence. The circumstantial evidence must exclude the possibility that some
other person has committed the offense.
Furthermore, it is the quality of the circumstances, rather than the quantity, that will
draw the line on whether the circumstances presented, consist of an unbroken chain
that will inescapably lead to the conclusion that the accused is guilty without an iota
of doubt.