People V Lara

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PEOPLE OF THE PHILIPPINES VS. LARA


G.R. NO. 199877
AUGUST13, 2012

DOCTRINE: The Judicial Affidavit Rule and the Guidelines on Pre-Trial do not totally proscribe the
submission of additional evidence even after trial had already commenced. The submission of evidence
beyond the mandated period in the Judicial Affidavit Rule is strictly subject to the conditions that: a) the
court may allow the late submission of evidence only once; b) the party presenting the evidence proffers a
valid reason for the delay; and c) the opposing party will not be prejudiced thereby.

FACTS: Arturo Lara was arrested and charged for the crime of Robbery with Homicide for stealing San
Sebastian Inc.’s money, in the amount of approximately Php 230,000.00, and for the death of one Joselito
Bautista while the alleged stealing happened. When police operatives seized Lara, the latter was placed in
a police line-up whereby Enrique Sumulong, Jeff Atie, and Virgilio Manacob identified him as the
perpetrator of the crime.

Before the Supreme Court he argued that he was not assisted by counsel when the police placed him in a
line-up to be identified by the witnesses for the prosecution and he maintains that the police line-up is part
of custodial investigation and his right to counsel had already attached.

ISSUE: Whether there is sufficient evidence to convict Lara

RULING: Yes, there is sufficient evidence to convict Lara.


Contrary to appellant's assertion, prosecution witness Sumulong actually saw him shoot Bautista, the
victim. Also, it is apparent from the assailed decision of the CA that the finding of guilt against Lara is
based on circumstantial evidence.

Not only direct evidence but also circumstantial evidence can overcome the presumption of innocence.
Direct evidence of the commission of the crime is not the only matrix wherefrom a trial court may draw
its conclusion and finding of guilt. Even in the absence of direct evidence, conviction can be had if the
established circumstances constitute an unbroken chain, consistent with each other and to the hypothesis
that the accused is guilty, to the exclusion of all other hypothesis that he is not.

It is not only by direct evidence that an accused may be convicted of the crime for which he is charged.
Resort to circumstantial evidence is essential since to insist on direct testimony would, in many cases,
result in setting felons free and denying proper protection to the community.

Here, the following circumstantial evidence are tellingly sufficient to prove the guilt of appellant:
 While the vehicle was at the intersection of Mercedes and Market Avenues, Pasig City, appellant
suddenly emerged and pointed a gun at prosecution witness Sumulong, demanding from him to
produce the bag containing the money.
 Prosecution witness Sumulong threw the bag to the victim who was then seated at the backseat of the
vehicle.
 The victim alighted from vehicle carrying the bag
 Appellant chased and fired several shots at the victim.
 The victim sustained several gunshot wounds.
 The police officers recovered from the scene of the crime six deformed empty shells.

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