People v. Sanota


 People v. Sanota

G.R. No. 233659

December 10, 2019


                The RTC and CA convicted John Sanota y Sarmiento, Deo Dayto y Genroga and Rolando Espineli y Acebo for the crime of Robbery with Homicide under Art. 294 of the RPC. From a distance of three (3) meters, Santiago overheard the three (3) appellants planning to raid a house in Hacienda. Abion also heard the same appellants saying that anyone who blocks their path will be killed. Thereafter, Abion entered his house and cooked food for dinner. Later, in the evening of the same day, appellant Espineli arrived at Abion's house and invited the latter to a birthday party in Don Jose, Santa Rosa, Laguna. After Abion asked pennission from his wife, he and appellant Espineli boarded a motorcycle owned and driven by the same appellant. Instead of going to Don Jose, Santa Rosa, Laguna, the motorcycle headed towards Hacienda, and after five (5) minutes of travelling, appellant Espineli parked the motorcycle beside the road and in front of the house of Don Alfonso Quiros Appellant Espineli told Abion to stay put as he had to talk to his fellow security guard inside the house of Quiros. After a few seconds, appellants Sanota and Dayto arrived and the two asked Abion where appellant Espineli was. Abion told them that appellant Espineli went inside the house of Quiros and, thereafter, appellants Sanota and Dayto went inside the same house. Abion followed appellants Sanota and Dayto, and when he was twenty (20) meters away from the house of Quiros, he saw appellant Espineli handing a gun to appellant Dayto, and the latter, with a gun in his possession, climbed the window of the same house. After five (5) minutes, Abion heard a gunshot and saw appellant Dayto come out of the window of the house of Quiros with a gun on his right hand and a "black thing" on his left. Appellants Sanota and Dayto then fled to the forest, while appellant Espineli proceeded to where the motorcycle was parked. Ab ion also went back to the motorcycle and pretended that he didn't witness the incident. Appellant Espineli drove the motorcycle and Abion alighted in Barangay Hernandez where the latter was told by the former to keep quiet. The following day, Abion heard from his neighbors that Quiros' house has been robbed and that the latter's son, Jose Miguel Quiros (Jose Miguel) was killed.


                Whether or not the CA erred in affirming the RTC


                Rule 113, Section 4 of the Rules on Evidence provides three (3) requisites that should be established to sustain a conviction based on circumstantial evidence: Section 4. Circumstantial evidence, when sufficient. - 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 commission of a crime, the identity of the perpetrator, and the finding of guilt may all be established by circumstantial evidence. The circumstances must be considered as a whole and should create an unbroken chain leading to the conclusion that the accused authored the crime. The determination of whether circumstantial evidence is sufficient to support a finding of guilt is a qualitative test not a quantitative one. The proven circumstances must be "consistent with each other, consistent with the hypothesis that the accused is guilty, and at the same time inconsistent with the hypothesis that he is innocent, and with every other rational hypothesis except that of guilt." Abion positively identified the three (3) accused present at the scene of the crime in the evening of March 31, 2011; Dayto' s clambering up the open window with a gun, the sound emanating from inside the house of a single gunshot, after which Dayto exited the open window with a gun and a laptop in tow, which he then handed to Espineli and Sanota. Abion overheard the accused's drunken conversation earlier that day regarding their plan to rob a residence in Hacienda 8 (where the Quiros residence was located) and that they would shoot anyone who blocks their path. He described how the arrived almost at the same time in the wooded area behind the Quiros residence, their acting together to implement entry onto the open window that Dayto scaled, and their fleeing into several directions after Dayto had exited the window with a gun and laptop in his hands.

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