Facts:

• Bernardino Gaffud, Jr., along with two unidentified individuals, was charged with the complex crime of double murder.
• The incident occurred on the evening of May 10, 1994, at Sitio Biton, Barangay Wasid, Municipality of Nagtipunan, Province of Quirino, Philippines.
• Victims Manuel Salvador and his daughter Analyn Salvador were killed when their house was set on fire.
• An eyewitness identified Gaffud, Jr. as one of the perpetrators.
• Gaffud, Jr. did not appear for the preliminary investigation despite being subpoenaed, leading to charges against him and two John Does.
• The prosecution presented six witnesses, including the common-law wife of Manuel Salvador, a barangay captain, a neighbor, a police investigator, and a doctor who conducted the autopsy.
• The defense presented Gaffud, Jr., his wife, and his in-law, who all testified to his alibi.
• The Regional Trial Court (RTC) found Gaffud, Jr. guilty of two counts of murder and sentenced him to death.
• The Court of Appeals (CA) affirmed the RTC's decision but modified it to a single death penalty for the complex crime of double murder.
• The case was elevated to the Supreme Court for review.

Issue:

• (Unlock)

Ruling:

1. The Supreme Court held that the failure to prove conspiracy was not fatal to the conviction of Gaffud, Jr.
2. The Supreme Court upheld the conviction of Gaffud, Jr. for the complex crime of double murder, r...(Unlock)

Ratio:

• The Supreme Court concurred with the CA that the lack of discussion on conspiracy did not negate Gaffud, Jr.'s conviction.
• The direct participation of Gaffud, Jr. in the crime was established beyond doubt by the prosecution's evidence.
• The circumstantial evidence presented was sufficient to sustain the conviction, meeting the criteria of having more than one circumstance, proven facts, and a combination of circumstances leading to a conviction beyond reasonable doubt.
• Gaffud, Jr. was seen near the crime scene, identified by an eyewitness, and had a motive due to a previous complai...continue reading