TITLE: Ungsod vs.

People
CITATION: 478 SCRA 282, G.R. No. 158904 December 16, 2005
TOPIC: Weight and Sufficiency of Evidence - Criminal Cases

FACTS:
X was charged with murder for the killing of Y. According to the 2 witnesses, after they left the comfort
room, the only persons left behind were X and Y. In addition, they estimated that with the size of the
comfort room, which he estimated to be 1 meter by 1.5 meters, or just enough to accommodate three
persons at a time. This was corroborated by P when he testified that the comfort room in his
establishment was very small and that it would already be crowded if two persons simultaneously make
use of the facility. These were used by the court to establish “an unbroken chain which leads to one fair
and reasonable conclusion which points to X as the one who shot Y.” Can the court convict X based on
circumstantial evidence?

ANSWER:
Yes.

Under Rule 133, Section 4, of the Rules of Court, it is stated that there is sufficiency in circumstantial
evidence when: 1) there is more than one circumstance; 2) the facts from which the inferences are
derived are proven; 3) the combination of all the circumstances is such as to produce a conviction beyond
reasonable doubt.

In this case, the circumstantial evidence presented by the prosecution warrants the finding of guilt of X.
TITLE: Marturillas vs. People
CITATION: 487 SCRA 273, G.R. No. 163217 April 18, 2006
TOPIC: Weight and Sufficiency of Evidence - Criminal Cases

FACTS:
X was charged with homicide and the trial court convicted him based on the victim’s dying declaration,
testimony of witnesses and several circumstantial evidence. X claims that there should have been no
finding of guilt because the paraffin test done on him yielded a negative result. Is X correct?

ANSWER:
No.

Conviction in a criminal case does not require a degree of proof that, excluding the possibility of error,
produces absolute certainty. Only moral certainty is required or that degree of proof that produces
conviction in an unprejudiced mind.

In this case, the totality of the evidence presented by the prosecution is sufficient to sustain the conviction
of X. Also, while the paraffin results were negative, that fact alone did not ipso facto prove that he was
innocent.
TITLE: People vs. Del Mundo
CITATION: 510 SCRA 554, G.R. No. 169141 December 6, 2006
TOPIC: Weight and Sufficiency of Evidence - Criminal Cases

FACTS:
X was criminally charged for violation of Sections 5 and 11, Article II of RA No. 9165. X was caught in
flagrante delicto during a buy-bust operation which was caused by a report from a confidential informant.
The police officers testified but the informant was never presented by the prosecution as witness during
the trial. X contends that the non-presentation should result to his acquittal. Is X correct?

ANSWER:
No.

The rule is that the presentation of the informant in an illegal drugs case is not essential for the conviction
nor is it indispensable for a successful prosecution because his testimony would merely be corroborative
and cumulative. Informants are generally not presented in court because of the need to hide their identity
and preserve their invaluable service to the police.

Here, the agents directly testified regarding the entrapment, and the testimony of the informant would
merely have been corroborative.