G.R. No. L-62871 May 25, 1984
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FELICITO TAWAT and LEO TAWAT, accused.

FACTS

This is an automatic review of the death sentence imposed on Felicito Tawat for Robbery with Triple Homicide. On January 23, 1980, the bodies of Bernarda Salvador and two boys, Lito Siao and Jose Magdaraog, were discovered in a hut in Sitio Banog, Catanduanes. They had sustained multiple fatal wounds. The scene indicated robbery, with a pig, chickens, a mosquito net, kitchenware, and Bernarda’s money belt missing. A pair of black shorts with a belt, later identified as belonging to Felicito Tawat, was found at the crime scene.
The prosecution’s case was built on circumstantial evidence. Floro Ogalesco testified that on January 24, 1980, Felicito and his cousin Leo Tawat arrived at his remote hut. Felicito confessed they had killed an old woman and two boys the previous night after a dog barked, provoking a confrontation, and that they had taken food and belongings. This account was partly corroborated by Alejo Tawat, Felicito’s father, who saw the accused cooking chickens and a pig on the morning after the crime. Felicito’s alibi that he was in Camarines Norte from 1963 was disproven by school records and his father’s testimony.

ISSUE

Whether the circumstantial evidence presented is sufficient to prove Felicito Tawat’s guilt for the complex crime of Robbery with Homicide beyond reasonable doubt.

RULING

Yes, the conviction is affirmed. The Supreme Court upheld the trial court’s finding that the totality of circumstantial evidence leads to a moral certainty of Felicito Tawat’s guilt. The established circumstances form an unbroken chain consistent only with the hypothesis of guilt: (1) Felicito’s spontaneous confession to Ogalesco detailing the killings and robbery; (2) the discovery of his personal shorts at the crime scene, linking him directly to the location; (3) the testimony of his father placing him and Leo with stolen property (chickens, pig, mosquito net) on the morning after the crime; and (4) Felicito’s own subsequent judicial confession in a separate case, where he admitted being wanted for killing three persons in Barrio Agban. His weak and fabricated alibi could not overcome this evidence. While no eyewitness testified, circumstantial evidence is sufficient for conviction if it meets the required criteria, which were satisfied here. The Court affirmed the penalty but, due to the lack of the necessary votes for its imposition, commuted the death sentence to reclusion perpetua. The award of civil indemnity was modified to include the value of the stolen articles.