Case Digest (G.R. No. 133737)
Facts:
The case is People of the Philippines v. Jonathan Diaz, G.R. No. 133737, January 13, 2003, the Supreme Court Second Division, Austria‑Martinez, J., writing for the Court. The accused-appellant is Jonathan Diaz; the prosecution is the People of the Philippines.An Amended Information filed August 26, 1996 charged Diaz with murder (Art. 248, Revised Penal Code) for the killing of Christie Joy Torres on October 14, 1995 at the Ateneo de Zamboanga. At arraignment Diaz pleaded not guilty and a full trial followed in the Regional Trial Court (RTC), Branch 13, Zamboanga City. The RTC rendered its decision on March 6, 1998 (Crim. Case No. 3192 / 13464) convicting Diaz of murder and sentencing him to reclusion perpetua and to pay civil indemnity, actual and moral damages and costs.
The prosecution presented eighteen witnesses, including medical officers (Drs. Henry Cawley and Concepcion Fabian), security and school personnel, several student eyewitnesses (Deborah Comille, Maria Coleen Lincoln, Janet Nalzaro, Jocelyn Partosa), faculty (Servando Halili, Evelyn Garcia), the victim’s parents, and police/NBI investigators. The prosecution’s narrative established: Diaz entered campus in the morning, was seen near the college building and mens comfort room on the second floor, and a female’s screams were heard; a large man wearing a white T‑shirt and maong pants emerged from Cubicle No. 2 wiping his face, briefly covered his face, passed by faculty and students who later identified him as Diaz, warned “Papatayin kita,” and shortly thereafter the unconscious body of Christie Joy Torres was found in Cubicle No. 2 and later pronounced DOA. Diaz was later identified from photographs shown at an emergency meeting and was eventually arrested on August 17, 1996 after months in hiding.
The defense presented medical and alibi witnesses (including Dr. Rodolfo Valmoria, psychiatrist Dr. Indah Taas Alpa, friends and family) and Diaz testified at length about his movements that day and his subsequent flight, claiming fear of arrest and a purported “shoot‑to‑kill” rumor; defense experts questioned whether the victim could have screamed given her injuries. The RTC convicted. Diaz appealed to the Supreme Court (on the RTC decision), assig...(Subscriber-Only)
Issues:
- Was the circumstantial evidence presented by the prosecution sufficient to sustain Diaz’s conviction for murder?
- Is proof of motive essential where conviction is based on circumstantial evidence in this case?
- Does Diaz’s flight and continued absence constitute an admission or circumstance of guilt justifying the inf...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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