Title
People vs. Biglete y Camacho
Case
G.R. No. 182920
Decision Date
Jun 18, 2012
A man is sentenced to reclusion perpetua without parole for murder, relying on circumstantial evidence and witness identification of the motorcycle involved.
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Case Digest (G.R. No. 182920)

Facts:

  • Michael Biglete y Camacho was charged with murder for the death of Arnel Alcos on August 27, 2001, in San Pablo City, Philippines.
  • The Information alleged that Biglete shot Alcos with an unlicensed firearm, causing fatal injuries.
  • Biglete evaded arrest for nearly three years until his capture on April 21, 2004.
  • He pleaded not guilty during his arraignment on May 6, 2004.
  • The prosecution relied on circumstantial evidence, including witness testimonies from Susan Alcos and Victor Andaya.
  • Witnesses reported seeing a motorcycle, later identified as belonging to Biglete, and its driver firing a gun at Arnel.
  • An abandoned motorcycle and a revolver were found near the crime scene.
  • Biglete claimed he was mauled and that his motorcycle was stolen, but his alibi was unsubstantiated.
  • The Regional Trial Court (RTC) convicted him of murder on July 11, 2006, citing treachery and the use of a motor vehicle as aggravating factors.
  • The Court of Appeals (CA) affirmed the RTC's decision on December 17, 2007, with modifications on qualifying circumstances and damages.

Issue:

  • (Unlock)

Ruling:

  • Yes, the circumstantial evidence was sufficient to establish Biglete's guilt beyond reasonable doubt.
  • The courts correctly recognized the qualifying circumstance of treachery but did not find evident premeditation.
  • The awards for civil ...(Unlock)

Ratio:

  • The Supreme Court stated that circumstantial evidence can establish guilt if it meets specific criteria in Section 4, Rule 133 of the Rules of Court.
  • Testimonies from Susan Alcos and Victor Andaya created a coherent narrative linking Biglete to the crime.
  • Susan identified Biglete as the shooter, and Victor corroborated her account regarding the motorcycle's color and the driver's clothing.
  • The combination of these testimonies, along with the discovery of the motorcycle and firearm, led to the conclusion of Biglete's guilt.
  • The Court agreed with t...continue reading

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