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BASCUGIN went to the SC alleging that there was insufficient evidence to hold him
guilty BEYOND reasonable doubt as the prosecution relied on circumstantial
evidence.
ISSUE:
Is BASCUGIN guilty beyond reasonable doubt?
HELD:
Yes. The decisive factor in BASCUGINs conviction was his admission to the crime
when he was examined by his lawyer in court. He testified as follows:
xxx
Q: Did you feel any remorse or resentment to what happened with you and [AAA]?
A: Yes, sir.
Q: I noticed also, Mr. Witness, that at the course of the proceedings of this case you
are always changing your plea of not guilty/to guilty. Why is it so, Mr. Witness?
A: Because I am bothered by my conscience and I was always changing my plea but
I feel responsible for what I did, sir.
Q: Do you know fully the consequences of your testimony, Mr. Witness?
A: Yes, sir.
ATTY. CHAVEZ: I have no more questions, Your Honor.
xxx
BASCUGINs confession was freely, intelligently, and deliberately given. Judicial
confession constitutes evidence of a high order. The presumption is that no sane
person would deliberately confess to the commission of a crime unless prompted to
do so by truth and conscience. Admission of guilt constitutes evidence against the
accused pursuant to the following provisions of the Rules of Court.
Furthermore, BASCUGINs confession is consistent with the evidence. We agree
with the trial and appellate courts finding that the chain of events constitutes
circumstantial evidence that is sufficient to support a conviction. From the
testimonies of witnesses and the physical evidence gathered, it was established
that the victim was last seen with BASCUGIN in his tricycle; his tricycle was seen
parked near a waiting shed in the premises of which the victims personal
belongings were later found; his pieces of clothing were found positive for human
blood that matches the victims; and the medico-legal report states that BASCUGIN
had sexual intercourse with the victim.
Circumstantial evidence is that evidence which proves a fact or series of facts from
which the facts in issue may be established by inference. According to Rule 133,
Section 4 of the Rules, circumstantial evidence is sufficient for conviction if: (1)
there is more than one circumstance; (2) the inference is based on proven facts;
and (3) the combination of all circumstances produces a conviction beyond
reasonable doubt of the guilt of the accused. In the case at bar, the circumstantial
pieces of evidence enumerated by the trial court all point to BASCUGIN as the
perpetrator beyond reasonable doubt.