Evidence: Weight and Sufficiency of

PEOPLE v DE OCAMPO Evidence

123 Syllabus topic; Iota of Evidence
G.R. No. 185212 February 15, 2012 Abad, J. MAKALINTAL, Katherine
Petitioner/s: Respondent/s:

PEOPLE OF THE PHILIPPINES, ALFREDO NARDO Y ROSALES

Summary

The Provincial Prosecutor of Sultan Kudarat charged the accused Maritess Alolod, Efren Deocampo,
Edwin Deocampo, and Elmer Deocampo with double murder before the Regional Trial Court (RTC) of
Isulan, Sultan Kudarat, Branch 19, in Criminal Cases 2531 and 2532.

Doctrine: Circumstantial evidence is sufficient for conviction if: (a) there is more than one
circumstance; (b) the facts from which the inferences are derived are proven; and (c) the combination
of all the circumstances is such as to produce a conviction beyond reasonable doubt. The
circumstances must constitute an unbroken chain that inexorably leads to one fair conclusion: the
accused committed the crime to the exclusion of all others. In this case, the Supreme Court affirmed
the conviction made by the RTC based on its findings that the accused was responsible for the murder
of the Alolod couple based on circumstantial evidence.
Facts

The prosecution evidence shows that Melanio and Lucena Alolod adopted accused Maritess and took
her into their home in Barangay Poblacion, Lebak, Sultan Kudarat. Maritess had two children with her
lover, Efren Deocampo, who was never allowed to set foot on her parents’ house since they loathed
him. In May 1998, the old couple, Melanio and Lucena, suddenly went missing.

Neighbors and relatives testified last seeing the old couple on May 27, 1998. A neighbor, Magdalena
Ato, recalled that the two were in good health. In fact, Melanio even went to market early in the day. At
around 8:30 that evening, as he was making his rounds, a security guard at Salaman Institute,
Demetrio Nebit, saw two men standing near the fence that separated the school from the Alolod house.
On seeing Nebit, the two hurried into a nearby toilet but the security guard followed and told them to
come out. Nebit identified one of the two to be Efren Deocampo, a former classmate, and his brother
Edwin.

At about 2:00 a.m. on the following day, May 28, Victor Ato, Magdalena’s husband, awakened to
strange sounds coming from the Alolod house just five to six meters away. Victor heard a woman
sobbing and what sounded like a pig being butchered. He looked out through the window but, seeing
no one, he just went back to bed. When Victor woke up at 5:30 a.m., he saw Efren at the kitchen of the
Alolod house.

Later that day, Magdalena had the chance to ask Maritess about the sounds coming from their house
during the night. Maritess explained that Melanio was ill and she was having a difficult time giving him
medicine. Maritess added that her parents had left for Cotabato City early that morning. Meantime, on
inspection that morning, the school security guard noticed that the cyclone wire of the fence where he
saw Efren and Edwin standing the night before had been cut. He reported the incident to the school
principal.

Annaliza Relles, the grandniece of the Alolods, noticed the absence of the old couple when she came
over that morning to cook for them. Only Maritess and her two children were there. Maritess told
Annaliza that her parents had left for a vacation. Annaliza tried to use one of the toilets in the house but
it was padlocked. Maritess told her to just use the other toilet.

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On May 29 Generita Caspillo, Maritess’ relative and close friend, stayed at the Alolod residence to
keep them company because according to Maritess, her father suffered a stroke and had to be brought
to Cotabato for medical treatment. While Generita was there, she noticed a pile of red soil near the well
at the garden.

On May 30 Annaliza and Generita saw Efren’s younger brothers Edwin and Elmer at the Alolod
residence. The next day, during their town fiesta, friends and relatives came by to visit the old couple
but Maritess told them that they had gone to Davao City and would not return until August 16 or 17. By
June the couple’s grandchildren who would stay at their house for school began arriving. They
observed the frequent presence of the Deocampo brothers in the house. Sometime in August, Generita
and her mother, Lucena’s sister, came to pay a visit. They saw Efren wearing Melanio’s wristwatch.
Maritess insisted that her parents were still in Davao for medical check-up.

Finally, on October 9, 1998 Francisco noticed a portion of the land planted with camote. Francisco
found the place unlikely for camote since it was shaded from the sun. Those who boarded at the house
said that it was Maritess and Efren who planted them. With the help of others, Francisco dug up the
suspected spot. There they found the decomposing bodies of Melanio and Lucena. Based on the post-
mortem report, Melanio was strangled with a wire; Lucena was stabbed.

Procedural History

On May 10, 2001 the RTC found the four accused guilty of murder of Lucena, with Efren and Edwin as
principals and Maritess and Elmer as accessories, in Criminal Case 2531 and of the murder of Melanio
in Criminal Case 2532. In each case, the RTC sentenced Efren and Edwin to suffer the penalty of
death, while Maritess and Elmer were sentenced to suffer the penalty of imprisonment for 4 years and
2 months of prision correccional, as minimum to 10 years of prision mayor, as maximum. The RTC also
ordered the accused to pay ₱50,000.00 to the heirs of Lucena and another ₱50,000.00 to the heirs of
Melanio, and to pay the costs.

While the case was on appeal, the Court of Appeals (CA) granted the request of Maritess and Elmer to
withdraw their appeals, leaving only those of Efren and Edwin for its consideration. On August 30, 2007
the CA rendered judgment in CA-G.R. CR-HC 00419, affirming with modification the RTC decision. The
CA reduced the penalty imposed on Efren to reclusion perpetua and on Edwin who was a minor to 10
years and 1 day of prision mayor, as minimum to 15 years and 1 day of reclusion temporal, as
maximum. In addition to the ₱50,000.00 granted by the RTC as civil indemnity in each of the cases, the
CA further ordered the additional payment of ₱25,000.00 as exemplary damages and another
₱25,000.00 as temperate damages for a total of ₱100,000.00 in each case, with the principals
severally liable for ₱60,000.00 and the accessories for ₱40,000.00 of this amount. Efren and Edwin
appealed to this Court. Edwin, however, on a letter to the Office of the Solicitor General dated
December 7, 2008, manifested his intention to withdraw his appeal. On August 26, 2009 the Court
granted Edwin’s withdrawal, leaving Efren as the sole accused-appellant in this case.

Issue/s Ruling
1. Whether or not the CA erred in affirming the RTC’s finding that accused Efren 1. No
was responsible for the murder of the Alolod couple based on circumstantial
evidence.
Rationale

The rule of evidence that applies when no witness saw the commission of the crime1 provides:

SEC. 4. Circumstantial evidence, when sufficient. – Circumstantial evidence is sufficient for conviction
if:

(a) There is more than one circumstance;

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(b) The facts from which the inferences are derived are proven; and

(c) The combination of all the circumstances is such as to produce a conviction beyond reasonable
doubt.

The circumstances must constitute an unbroken chain that inexorably leads to one fair conclusion: the
accused committed the crime to the exclusion of all others.2

Here, those circumstances abound.

1. Efren had always been banned from the old couple’s house because they strongly disapproved his
relationship with Maritess, their adopted daughter so he had no business being around that house.

2. The old couple were enjoying good health before the evening of May 27, 1998.

3. On May 28 they were suddenly gone from the house, meaning that they were killed on the night of
May 27 or early morning of May 28.

4. On the night of May 27 the security guard at Salaman Institute saw Efren and Edwin standing on the
school side of the fence next to the old couple’s house. They even tried to conceal themselves in the
school toilet. The next day, the guard discovered that the fence wire had been cut.

5. At about 2:00 a.m. of May 28 a neighbor heard the sound of a woman sobbing and what seemed like
the butchering of a pig.

6. At break of dawn, a witness saw Efren in the Alolod kitchen.

7. From then on Efren and his brothers frequented the old couple’s house, with Efren wearing the old
man’s watch.

8. Maritess definitely lied about her adoptive parents going to Cotabato City and subsequently to Davao
City for medical treatment when people started looking for them. They were of course buried in the
garden.

9. A witness heard Efren instructing Maritess to plant more camote on a pile of red soil beside the
house.

10. The bodies of the old couple were found underneath those plants.

The alibi of Efren that he was in Maguindanao at about the time the old couple was killed does not
encourage belief.1âwphi1 The security guard saw him with his brother at 8:30 p.m. of May 27 near the
couple’s house where they had no business being there. A neighbor saw Efren at the kitchen of that
house on the morning following the slaying of the couple. And it was not physically impossible for the
accused to be at the crime scene when it happened.3 Sitio Gila-gila, South Upi, Maguindao was merely
15 kilometers from Lebak, Sultan Kudarat.

The CA, however, correctly reduced the imposable penalty from death to reclusion perpetua, not only
because the information failed to allege the aggravating circumstances of dwelling and the victims’ age
but likewise, because of Republic Act 93464 that now prohibits the imposition of the death penalty.

Disposition

WHEREFORE, the Court AFFIRMS the decision of the Court of Appeals in CA-G.R. CR-HC 00419
dated August 30, 2007 with MODIFICATION ordering accused Efren Deocampo to indemnify the heirs
of Melanio and Lucena Alolod

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