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G.R. No. 206236 July 15, 2013 GILFREDO BACOLOD, A.K.A. GILARDO BACOLOD, Accused-Petitioner, PEOPLE OF THE PHILIPPINES, Plaintiff-Respondent

The Supreme Court upheld Gilfredo Bacolod's conviction for arson. [1] Eyewitness Ruben Gonzales testified that he saw Gilfredo arguing with his sister about money, saw Gilfredo waving a flaming blanket in the kitchen of the rented house, and saw the fire spread after he turned off the stove. [2] Circumstantial evidence can be sufficient to convict someone of a crime if it forms an unbroken chain of events leading to the person's guilt. [3] In this case, the circumstantial evidence established Gilfredo's guilt beyond a reasonable doubt.

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102 views2 pages

G.R. No. 206236 July 15, 2013 GILFREDO BACOLOD, A.K.A. GILARDO BACOLOD, Accused-Petitioner, PEOPLE OF THE PHILIPPINES, Plaintiff-Respondent

The Supreme Court upheld Gilfredo Bacolod's conviction for arson. [1] Eyewitness Ruben Gonzales testified that he saw Gilfredo arguing with his sister about money, saw Gilfredo waving a flaming blanket in the kitchen of the rented house, and saw the fire spread after he turned off the stove. [2] Circumstantial evidence can be sufficient to convict someone of a crime if it forms an unbroken chain of events leading to the person's guilt. [3] In this case, the circumstantial evidence established Gilfredo's guilt beyond a reasonable doubt.

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Jas Paras
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G.R. No.

206236               July 15, 2013

GILFREDO BACOLOD, a.k.a. GILARDO BACOLOD, Accused-Petitioner,


vs.
PEOPLE OF THE PHILIPPINES, Plaintiff-Respondent.

 ACCUSED- Gilfredo Bacolod (arson)

 VICTIM- Cogtas spouses (sa kanila yung bahay na sinunog)

 Witness Ruben Gonzales was a neighbor. He described the following chain of


circumstances:

o Cogtas spouses were renting out a house. Gilfredo was tenant.

o Ruben heard a commotion/argument between Gilfredo and his sister about money.

o He was only “15 arm’s length” away from the Cogtas house

o Ruben saw Gilfredo’s sister and three other people running out of the house asking
for help

o Ruben went towards the house to see what was happening and saw Gilfredo in the
kitchen waving a flaming blanket that he had lit from the burner stove, coming out of
the house, and daring anyone to arrest him

o Ruben turned off the burner stove in the kitchen, even as he saw the ceiling of the
kitchen already in flames, but the fire immediately spread to the other parts of the
house

o All of this was also corroborated by their barangay tanod

 Gilfredo insists that no witness had actually seen him set the house on fire, and that only
circumstantial evidence was presented against him.

ISSUE: Whether the chain of circumstantial evidence was enough to convict Gilfredo of arson.

HELD: Yes. [parang similar case/ruling lang sa Bacerra vs People last week]

 The lack or absence of direct evidence does not necessarily mean that the guilt of the
accused cannot be proved by evidence other than direct evidence. Direct evidence is not the
sole means of establishing guilt beyond reasonable doubt, because circumstantial evidence,
if sufficient, can supplant the absence of direct evidence. The crime charged may also be
proved by circumstantial evidence, sometimes referred to as indirect or presumptive
evidence. Circumstantial evidence has been defined as that which "goes to prove a fact or
series of facts other than the facts in issue, which, if proved, may tend by inference to
establish a fact in issue."
 Reliance on circumstantial evidence was sanctioned by Rule 133, Section 4 of the Rules of
Court, which requires for circumstantial evidence to warrant the conviction of an accused
that:

o firstly, there are more than one circumstance;

o secondly, the facts from which the circumstances arose are duly established in court;
and,

o thirdly, the circumstances form and unbroken chain of events leading to the fair
conclusion of the culpability of the accused for the crime for which he is convicted.

 Our rules "make no distinction between direct evidence of a fact and evidence of
circumstances from which the existence of a fact may be inferred. No greater degree of
certainty is required when the evidence is circumstantial than when it is direct, for in either
case, the trier of fact must be convinced beyond a reasonable doubt of the guilt of the
accused."

 Thus, Gilfredo’s conviction of arson is proper.

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