G.R. No. L-36309 - IN RE: Malkinson vs. Agrava

The case involves appellant Rex T. Canlas who was charged with the special complex crime of robbery with homicide.
The incident involved the robbery and subsequent killing of Jing Garcia Flores, whose personal merchandise and cash were taken.
The prosecution’s Information alleges that on June 14, 1998, in Brgy. Palat, Porac, Pampanga, a group of accused (including Canlas) conspired to steal merchandise and cash from the victim and, during the robbery, used violence that resulted in Flores’ death.

On the afternoon of June 14, 1998, Jing Garcia Flores was last seen alive entering a small alley near the house of Jose Tamayo.
Subsequent search by companions and barangay officials led to the discovery of the victim’s body in a creek on the morning of June 15, 1998.

Several items belonging to the victim (including a white Hanes t-shirt, blue sandals, a “Bench” cap, a red towel, and assorted clothings) were found inside Jose Tamayo’s house, specifically under a bamboo bed in a room said to be frequented by the accused.
A lead pipe with bloodstains and a hunting knife recovered from the scene were presented as part of the physical evidence.
Dr. Olga Bausa’s forensic exam confirmed the presence of human blood on most items, and Dr. Lilia Panlilio’s autopsy revealed that the victim died from intracranial hemorrhages due to blunt force trauma.

SPO2 Henry Ayson, along with other law enforcement officials, provided an account detailing the discovery of the victim’s body, the chain of blood-stained evidence, and the recovery of the victim’s personal effects from the house of Jose Tamayo.
Testimony of residents and accompanying barangay officials described the search process and the observations regarding the victim’s last known movements.
A witness, Ismael Victoria, testified that he saw Rex Canlas standing under a tree near the said house around the time the victim was last seen, thereby challenging the defendant’s alibi.
The supposed statement of Lucila Tamayo (the accused’s grandmother) was noted by the investigating officer but was not presented in court, rendering it hearsay.

Rex Canlas asserted that he was in Metro Manila on the day of the incident, having traveled from his workplace in Pasig after attending his cousin’s birthday celebration in Porac early in the morning.
He denied any involvement in the crime, maintained that he did not sleep on the bamboo bed reportedly used in the case, and reiterated his claim of having left Palat well before the robbery occurred.

The defense contended that there was no direct physical evidence linking him to the scene nor demonstration of his active participation in the events leading to Flores’ death.

The trial court’s decision was based heavily on numerous pieces of circumstantial evidence, which it claimed formed an “unbroken chain” leading to the conclusion that Canlas was present at the scene and involved in both the robbery and homicide.
Key evidentiary points relied upon:

The victim’s disappearance and last sighting in proximity to the house of Jose Tamayo.
Testimonies establishing that items belonging to the victim were recovered from inside that house, including bloodstained clothing and a lead pipe.
The observation of Canlas near the scene during the search for the victim, which ostensibly refuted his alibi.
The alleged testimony of the accused’s grandmother which implicated Canlas in the commission of the robbery and homicide, despite its status as hearsay.

Despite the evidence, it was noted that the chain of circumstances did not irrefutably show that Canlas was the perpetrator and did not discount the possibility of another person’s involvement.

Whether the assembly and combination of circumstantial evidence presented by the prosecution constitute an unbroken chain proving guilt beyond reasonable doubt.
Whether the circumstantial evidence against Canlas was strong and consistent enough to exclude alternative explanations or other potential perpetrators.

Whether the trial court erred in giving weight to evidence (e.g., witness observations and hearsay statements) that was speculative or inadequately corroborated.
Whether the trial court failed to adequately appreciate and give due consideration to the defense evidence, particularly the alibi and the absence of direct physical evidence linking Canlas to the crime scene.