People vs. Uy

Robbery with homicide may be established by circumstantial evidence where the proven circumstances form an unbroken chain pointing to the accused, to the exclusion of all others, as the guilty person; aggravating circumstances not alleged in the information cannot be appreciated even if proven during trial. All principals in the robbery are liable for the single indivisible felony of robbery with homicide even if they did not actually take part in the killing, unless they clearly endeavored to prevent it.

Antonio Manuel Uy was a member of the maintenance crew of Jeepney Shopping Center, a business owned by Jerry Limpe, and had formerly been a stay-in employee there. The case involves the special complex crime of robbery with homicide under Article 294 of the Revised Penal Code, as amended by Republic Act No. 7659, punishable by reclusion perpetua to death.

Antonio Manuel Uy worked as part of the maintenance crew at the Jeepney Shopping Center on Taft Avenue, Pasay City, owned by Jerry Limpe; he had been a stay-in employee until his co-employees asked that he leave the employees’ quarters, after which he rented a house on Sandejas Street, Pasay City. After he was removed from the quarters, Cecilio Aranez heard Uy threaten, “Balang araw makagaganti ako.” Sometime in the first week of June 2001, Uy’s co-employees, including Neptali Tamayo, had a drinking spree at Juz Café along Taft Avenue, Pasay City, until 3:00 o’clock in the morning; on their way home, they noticed two persons outside the guardhouse of the Jeepney Shopping Center peeping inside, one of whom was Uy, and when the group approached them, they hid themselves inside the guardhouse; later, Uy came out and uttered a joke, and then he and his companion left. Around 9:00 o’clock in the morning of June 26, 2001, Uy sent a text message to Roger Tan, the Supervisor of the Maintenance Department, that he was not feeling well and would not report for work. Around 11:00 o’clock in the evening, Joel Adol, the security guard of Chang Juat Ltd. Company located at No. 1906, Taft Avenue, Pasay City, saw Uy with a companion standing at the gate of the Jeepney Shopping Center; Adol had a clear and unobstructed view because Chang Juat Ltd. Company was adjacent to the shopping center and the area was brightly lighted, and he recognized Uy because he used to see him cleaning the premises and directing traffic; Adol observed Uy and his companion looking at his post and peeping inside the shopping center, and when Adol went inside the building around 12:00 o’clock in the evening, they were still at the gate.

Around 5:30 in the morning of June 27, 2001, Carpio Bahatan, a stay-in employee of the Jeepney Shopping Center, discovered the lifeless bodies of Felix Aranez and Delfin Biniahan at the second floor and third floor, respectively, of the main building; another stay-in employee, Rico Victor Arbas, discovered the dead body of security guard Gilbert Esmaquilan near the guardhouse inside the compound. A piece of wood with blood stains was found about three to five meters from Esmaquilan’s body, and another blood-stained piece of wood was found in the locker room within the compound but outside the main building. At the opening leading to the comfort room on the ground floor, pieces of jalousie slabs and frames were scattered on the ground. At the second floor, Aranez’s body was lying face down with feet and hands tied with yellow plastic straw; a piece of cloth was stuck in his mouth and his nape had an incise wound; a bunch of keys was found inside the display cabinet which was in disarray, and some pieces of jewelry inside the display cabinet were missing. At the third floor, Biniahan’s body was lying on a folding bed between two glass cabinets; he sustained injuries on the upper part of his body, the glass cabinets were splattered with blood, and the door of the Administrative Office had been destroyed and bore traces of blood. Police Senior Inspector Emmanuel Reyes conducted autopsies: Aranez sustained a hack wound on the nape measuring 0.3 cm. x 0.7 cm., which could have been caused by a bladed weapon, and hematoma on the occipital region measuring 8 cm. x 8 cm., and on the frontal region just above the right eye which may have been caused by a blunt object; Biniahan sustained five lacerated wounds on the frontal region and his lower jaw was displaced toward the left side, which could have been caused by a hard blow; the cause of death of Aranez and Biniahan was “intracranial hemorrhages secondary to traumatic injuries of the head.” Esmaquilan sustained multiple stab wounds on the left mammary region piercing the aorta near its attachment to the heart, the left subcostal region piercing the stomach, the vertebral region, the left posterior rib, the right infrascapular region, and the right costal region; the fatal wounds were those which pierced his heart and lungs, and the cause of death was “hemorrhage and shock secondary to multiple stab wounds of the body.”

Around 8:30 in the evening of June 28, 2001, Uy met his girlfriend Richlie Ladiana at her workplace in Panorama Street, SSS Village, Marikina City, and gave her ₱6,000.00; Uy was with Ricky Ladiana, Richlie’s brother, and Richlie noticed that Uy appeared to have a problem while Ricky looked stern; after giving the money, Uy and Ricky immediately left. Around 8:30 in the morning of June 29, 2001, Uy called Richlie and asked her to drop by Ricky’s house in Cupang, Antipolo City; at 8:57 that morning, Uy sent a text message to Roger Tan reading, “Boss, Gud morning. Bukas na ako papasok o kaya Lunes ang sama talaga ng trangkaso nabasa K C ako ng ulan nong Martes pag diliver namin,” and at 9:57 he sent another message reading, “Boss, balita daw na ako ang suspek sa nangyari dyan boss matagal na ako sa companya kahit alam kong inaapi ako nyo wala akong ginawa na masama sa trabaho ko.” When Richlie arrived at Ricky’s house, Uy gave her ₱500.00 and asked her to buy him tee-shirts and shorts; he also asked her to return the ₱6,000.00 because he was leaving for the province. Around 2:30 in the afternoon, Richlie returned before going to school; Uy asked her not to attend her classes anymore because he was leaving, and she stayed with him until 7:00 o’clock in the evening; while Uy was putting on his clothes, Richlie noticed he was wearing a cross pendant, and thereafter he handed her something wrapped in a newspaper containing 4 pairs of earrings, a pairless earring, and 5 ladies’ rings. Around 9:00 that evening, Uy and Ricky went to the house of Eduardo dela Cruz in Cupang, Antipolo City; Eduardo was the second cousin of the mother of Richlie and Ricky; Ricky looked very nervous and his eyes were reddish, while Uy was very quiet; Ricky told Eduardo that they were in trouble and asked him to accompany Uy to the house of Panfilo dela Cruz, Eduardo’s first cousin, in Sitio Tibol, Barangay Salasa, Palauig, Iba, Zambales, because Uy would stay there for two to three days, and Eduardo agreed. Eduardo and Uy proceeded to the Victory Liner terminal in Cubao, Quezon City; when they arrived around 11:30 that evening, the last trip for Zambales had left, so Uy told Eduardo they would get a taxi to Olongapo City; they hired a taxi for ₱1,500.00 and arrived in Olongapo City around 1:00 o’clock in the morning of June 30, 2001; while waiting for a bus, they drank coffee, and Eduardo asked Uy what happened; Uy confessed that he and Ricky entered a place in Pasay City and killed two persons and seriously wounded another whom they left fighting for his life; Uy also told Eduardo about the vault which contained money and that if “he can open the vault, and even if they die their family will live comfortably,” and that nothing would be traced to him because his hands were wrapped so that no fingerprints would be recovered. They arrived at Panfilo dela Cruz’s house around 6:00 o’clock in the morning; Eduardo introduced Uy and said he would stay for about two days, and at noontime Eduardo went back to Manila.

After a week, Eduardo went to SPO3 Rodrigo Urbina of the PNP Regional Mobile Patrol Group and told him what Uy had confessed and that he had brought Uy to Zambales; SPO3 Urbina coordinated with the Pasay City Police Station, Crime Investigation Division, for Uy’s arrest. Around 5:00 o’clock in the morning of July 12, 2001, a joint team of the Regional Mobile Patrol Group, the Pasay City Police Station, and the Palauig Police Station arrested Uy in Panfilo dela Cruz’s house; Uy was frisked and a cross pendant was recovered from his pocket. The inventory conducted by Cresilda Tigolo, the accounting clerk of Jeepney Shopping Center, revealed that 191 pieces of jewelry worth ₱304,140.00 and 2 imported bags worth ₱23,250.00 were stolen, for a total value of ₱327,390.00. The gold pendant recovered from Uy was worth ₱3,400.00; also recovered were a diamond earring worth ₱6,700.00 and a diamond ring worth ₱5,450.00 which Richlie had pawned through a friend, Wilfredo Mazo, and which were recovered from Villarica Pawnshop, Inc., in Marikina City; the total amount of recovered jewelry was ₱15,550.00. The .38 Caliber Armscor revolver service weapon of victim Gilbert Esmaquilan, owned by Energetic Security Specialist, was recovered by PO3 Edison Cabotaje in Ricky Ladiana’s house. The Honda VTEC 1999 model car with plate no. WFD 891, owned by Oliver Gatchalian, which had been used as the “getaway” car by Uy, was recovered somewhere in Quezon City.

Uy denied the charge. He testified that on June 26, 2001, he called up Jeepney Shopping Center to inform them that he was sick; he later decided to go to the house of his niece Lea Ezra Uy in Caloocan to have a massage, and he was there from 8:30 p.m. until the following morning. At noontime of June 27, 2001, Richlie called him asking for money to pay for her tuition fee; at around 7 p.m., he met her in Marikina and gave her ₱6,000.00. On June 28, 2001, Uy went to Richlie’s place and saw her and Ricky arguing about an incident that happened at Jeepney Shopping Center; Richlie showed him a newspaper where his name appeared as a suspect; Ricky put his arms around him saying “huwag ka na lang maingay”; Uy told Ricky that he could not keep quiet because he was afraid he might be implicated since he knew that Ricky and his companions were the ones responsible for the incident; Ricky then gave him a package containing two pairs of earrings and three pieces of rings, but he declined to accept them as he already had many. After a while, Eduardo dela Cruz arrived and invited them to drink; Eduardo told him that he should be acquainted with Richlie’s relatives in Zambales; although Uy knew he only had three days leave, he agreed to go with Eduardo to Zambales; before leaving, he gave the pieces of jewelry which Ricky gave him to Richlie, and Richlie gave him back the ₱6,000.00 saying he might need the money for his trip. Around 9 p.m. of June 29, 2001, Uy and Eduardo rode a taxi going to Olongapo City; Uy slept the whole trip, and then they boarded a bus to Zambales; they reached Panfilo dela Cruz’s house around 4 a.m. the following day, and Eduardo introduced him to Panfilo as Richlie’s fiancé; after breakfast, Eduardo told him he was going back to Manila and would fetch him after two or three days. On July 12, 2001, three policemen entered his room and arrested him; they brought him to the Zambales Police Station, where PO3 Michael Manarang took a pendant from his pocket and told him that he already had evidence against him; Uy claimed he was tortured to admit the crime.

• Sufficiency of Evidence: Appellant argued that the RTC gravely erred in convicting him of the crime charged despite the fact that his guilt was not proven beyond reasonable doubt.
• Possession of Stolen Jewelry: Appellant argued that he satisfactorily explained his possession of the stolen pieces of jewelry because Ricky insisted on giving them to him, and he left them with Richlie out of fear of implication; he also claimed that the cross pendant was planted on him by PO3 Michael Manarang.
• Insufficiency of Richlie’s Testimony: Appellant argued that even if Richlie’s allegation that the pieces of jewelry she pawned came from him were true, the stolen items did not prove his culpability for robbery with homicide.
• Oral Confession: Appellant argued that his alleged confession to Eduardo dela Cruz was insufficient because it merely established an intention to rob a vault at an unspecified place and did not state who between him and Ricky committed the killings.
• Text Messages: Appellant argued that the text messages he sent to Roger Tan and Bernardo Cruz did not prove that he was responsible for the robbery with homicide.
• Recovery of Firearm: Appellant argued that the recovery of the service firearm of the slain security guard Esmaquilan at Ricky’s house did not prove his participation in the crime, and he pointed to Ricky and his companions as the ones responsible.
• Alibi: Appellant argued that he was at the house of his niece Lea Ezra Uy in Caloocan from 8:30 p.m. of June 26, 2001 until the following morning, and thus could not have been at the scene of the crime.
• Penalty: Appellant argued that, assuming arguendo he was guilty, the RTC erred in imposing the death penalty.

• Sufficiency of Evidence: Whether the prosecution proved beyond reasonable doubt that appellant committed robbery with homicide through circumstantial evidence and conspiracy.
• Possession of Stolen Jewelry and Cross Pendant: Whether appellant satisfactorily explained his possession of the stolen jewelry and cross pendant, and whether such possession supported his conviction.
• Oral Confession: Whether appellant’s oral confession to Eduardo dela Cruz was admissible and sufficient to establish his participation and intent to rob.
• Text Messages and Flight: Whether appellant’s text messages and sudden trip to Zambales indicated guilt.
• Recovery of Firearm: Whether the recovery of the slain guard’s firearm at Ricky’s house proved appellant’s participation in the crime.
• Alibi: Whether appellant’s alibi could overcome the prosecution’s evidence.
• Penalty and Damages: Whether the death penalty was proper and whether moral damages should be awarded.

• Sufficiency of Evidence: Yes. The prosecution established the elements of robbery with homicide and conspiracy through circumstantial evidence forming an unbroken chain pointing to appellant.
• Possession of Stolen Jewelry and Cross Pendant: No. Appellant’s explanations did not inspire belief; possession of stolen items gave rise to a presumption of guilt; the alleged planting of the cross pendant was not proven.
• Oral Confession: Yes. The oral confession to a private person was admissible and sufficient; all principals in the robbery are liable for the homicide unless they tried to prevent it.
• Text Messages and Flight: Yes. The contradictory excuses and unexplained flight to Zambales indicated a guilty mind.
• Recovery of Firearm: Yes. The recovery of the firearm at Ricky’s house, together with appellant’s companionship with Ricky and the other circumstances, established their joint participation.
• Alibi: No. The alibi failed the strict requirements of time and place and was overcome by positive testimony and circumstantial evidence.
• Penalty and Damages: No death penalty; reclusion perpetua is proper because no aggravating circumstance was alleged; moral damages of ₱50,000.00 each are awarded.

• Sufficiency of Evidence: The SC applied the elements of robbery with homicide: (1) taking of personal property with violence or intimidation against persons; (2) the property belongs to another; (3) the taking is animo lucrandi; and (4) homicide is committed on the occasion or by reason of the robbery. It held that intent to rob must precede the taking of human life, but the killing may occur before, during, or after the robbery, and there must be a nexus between the robbery and the killing. Direct evidence was not required; under Section 4, Rule 133, circumstantial evidence sufficed because there was more than one circumstance, the facts were proven, and their combination produced conviction beyond reasonable doubt. The SC found the elements and conspiracy proven from the missing jewelry, the destroyed cabinets and lock, Uy’s statement about the vault, his presence near the scene, his possession of stolen items, his flight, and the recovery of the guard’s firearm at Ricky’s house.
• Possession of Stolen Jewelry and Cross Pendant: The SC rejected Uy’s explanation as unbelievable. He claimed he declined Ricky’s gift of jewelry yet kept the items and gave them to Richlie; Richlie testified that Uy gave her a newspaper-wrapped package containing 4 pairs of earrings, a pairless earring, and 5 rings, and instructed her to pawn the items. The pawned diamond ring and earring were recovered from Villarica Pawnshop and proved to be part of the stolen items. The cross pendant was recovered from Uy’s pocket; PO3 Manarang and PO3 Cabrega testified on the search and recovery, and Richlie corroborated that she saw Uy wearing the pendant before his arrest. The presumption of regularity in official duties was not overcome, and the recovery of stolen items gave rise to a legal presumption of guilt which Uy failed to overcome.
• Oral Confession: The SC held that Uy’s oral confession to Eduardo dela Cruz, a private person and not a police officer, was admissible. A declaration of an accused acknowledging guilt may be given in evidence against him, and any competent witness who heard the confession may testify to its substance. The confession was not covered by the custodial investigation rights under Article III, Sections 12(1) and (3) of the Constitution because Uy was not under custodial investigation when he made it. Eduardo testified that Uy admitted he and Ricky entered the Jeepney Shopping Center to open the vault, killed three people, and believed no fingerprints would be recovered. The SC also held that all who take part as principals in the robbery are liable for the single indivisible felony of robbery with homicide even if they did not actually kill, unless they clearly tried to prevent the killing; there was no showing Uy attempted to prevent the killings.
• Text Messages and Flight: The SC found Uy’s text messages and conduct indicative of guilt. On June 29, 2001, Uy texted Roger Tan that he would report for work the following day or Monday because of fever, then texted again that he learned he was a suspect and had done nothing wrong. On July 1, 2001, he texted Bernardo Cruz asking why he was considered a suspect when he and his wife were on their honeymoon. The SC found these excuses contradictory and untruthful. Despite knowing he was a suspect in a serious crime, Uy did not report for work and instead left for Zambales on the night of June 29, 2001, hiding there until his arrest on July 12, 2001. The SC held that flight per se cannot prove guilt, but when considered with other circumstances, it may be a strong indication of guilt; unexplained flight gives rise to an inference of guilt.
• Recovery of Firearm: The SC held that the recovery of the slain security guard’s firearm at Ricky’s house, taken with the other circumstances, established Uy’s participation. Joel Adol positively identified Uy with a companion at the Jeepney Shopping Center gate around 11 p.m. of June 26, 2001, the night before the crime was discovered. Richlie testified that Uy was with Ricky on June 28 and 29, 2001, and Eduardo testified that Ricky brought Uy to him and asked him to bring Uy to Zambales because they were in trouble. Ricky and his family packed their things and left their house on June 30, 2001. The SC found these actuations were not the normal behavior of innocent men and, together with the firearm recovery, established that Uy and Ricky were together in committing the crime.
• Alibi: The SC held that Uy’s alibi failed because it did not meet the strict requirements of time and place. Uy claimed he was at his niece Lea Ezra Uy’s house in Caloocan from 8:30 p.m. of June 26, 2001 until the following morning, but he presented no corroborating witness and failed to show that it was physically impossible for him to be at the crime scene, considering that Caloocan would only be more than an hour’s travel to Pasay City at nighttime. Joel Adol positively declared that he saw Uy with a companion at the Jeepney Shopping Center around 11 p.m. of June 26, 2001, and positive testimony prevails over negative testimony.
• Penalty and Damages: The SC held that the RTC erred in appreciating nocturnity and treachery because they were not specifically alleged in the information. Sections 8 and 9 of Rule 110 of the 2000 Revised Rules on Criminal Procedure require aggravating circumstances to be alleged in the information; otherwise, they cannot be considered even if proven during trial. Robbery with homicide is punishable under Article 294, as amended by Republic Act No. 7659, by reclusion perpetua to death. Under Article 63 of the Revised Penal Code, when the law prescribes two indivisible penalties and the crime is neither attended by mitigating nor aggravating circumstances, the lesser penalty is imposed; thus, reclusion perpetua was proper. In robbery with homicide, civil indemnity and moral damages of ₱50,000.00 each are granted automatically in the absence of qualifying aggravating circumstances, without need of allegation and evidence other than the death of the victim. The SC affirmed the civil indemnity, added moral damages, and affirmed the reparation and funeral expenses.

• Robbery with homicide — The special complex crime exists when homicide is committed by reason or on the occasion of robbery. The elements are: (1) taking of personal property with violence or intimidation against persons; (2) the property belongs to another; (3) the taking is animo lucrandi or with intent to gain; and (4) homicide is committed on the occasion or by reason of the robbery. The intent to rob must precede the taking of human life, but the killing may occur before, during, or after the robbery; there must be a nexus between the robbery and the killing. The SC applied this to Uy because jewelry was taken, the taking was attended by violence, and three persons were killed on the occasion of the robbery.
• Circumstantial evidence — Circumstantial evidence proves a fact or series of facts from which the facts in issue may be established by inference. Under Section 4, Rule 133, the requisites are: (1) there must be more than one circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all circumstances is such as to produce a conviction beyond reasonable doubt. A conviction based on circumstantial evidence can be sustained when the circumstances form an unbroken chain pointing to the accused, to the exclusion of all others, as the guilty person. The SC applied this because there was no direct evidence but the circumstances established conspiracy and participation.
• Conspiracy and liability in robbery with homicide — Whenever homicide is committed by reason or on the occasion of robbery, all those who took part as principals in the robbery are liable as principals of the single and indivisible felony of robbery with homicide, although they did not actually take part in the killing, unless it clearly appears that they endeavored to prevent the same. The SC applied this because Uy and Ricky conspired, and there was no showing Uy tried to prevent the killings.
• Admissibility of oral confession to a private person — The declaration of an accused acknowledging his guilt of the offense charged, or of any offense necessarily included therein, may be given in evidence against him. An oral confession made to a private person who is not a police officer is admissible, and any person otherwise competent as a witness who heard the confession may testify as to its substance. The SC applied this to Eduardo dela Cruz’s testimony because Uy was not under custodial investigation when he confessed.
• Presumption from possession of stolen property — The recovery of stolen items from the accused gives rise to a legal presumption of guilt, which the accused must overcome by a satisfactory explanation. The SC applied this because Uy possessed stolen jewelry and the cross pendant, and his explanations were not credible.
• Flight — Flight per se cannot prove guilt, but when considered in light of other circumstances, it may be a strong indication of guilt; unexplained flight is a circumstance from which an inference of guilt may be drawn. The SC applied this because Uy left for Zambales after learning he was a suspect and hid there until his arrest.
• Alibi — Alibi must meet the strict requirements of time and place: the accused must show that he was not at the scene of the crime at the time it was committed and that it was physically impossible for him to have been at the scene at that time. The SC applied this because Uy failed to corroborate his alibi and failed to show physical impossibility.
• Aggravating circumstances must be alleged in the information — Under Sections 8 and 9 of Rule 110 of the 2000 Revised Rules on Criminal Procedure, aggravating circumstances must be alleged in the information; otherwise, they cannot be considered against the accused even if proven during trial. The SC applied this to disregard nocturnity and treachery, reducing the penalty to reclusion perpetua.
• Civil indemnity and moral damages in robbery with homicide — In robbery with homicide, civil indemnity and moral damages of ₱50,000.00 each are granted automatically in the absence of qualifying aggravating circumstances; these awards are mandatory without need of allegation and evidence other than the death of the victim owing to the commission of the crime. The SC applied this by affirming civil indemnity and awarding moral damages.

• “Robbery with homicide exists when a homicide is committed either by reason, or on occasion, of the robbery.” — This defines the special complex crime and serves as the starting point for the SC’s elements-based analysis.
• “A judgment of conviction based on circumstantial evidence can be sustained when the circumstances proved form an unbroken chain that results to a fair and reasonable conclusion pointing to the accused, to the exclusion of all others, as the guilty person.” — This states the standard that allowed the SC to affirm conviction despite the absence of direct evidence.
• “Appellant's confession to Eduardo, who is not a police officer, is admissible in evidence.” — This resolves the admissibility of the oral confession made to a private person and not during custodial investigation.
• “Considering that there was no modifying circumstance which attended the commission of the crime, the CA correctly modified the penalty to reclusion perpetua.” — This explains why the death penalty was reduced after the aggravating circumstances were disregarded for not being alleged.

• People vs. Baron, G.R. No. 185209, June 28, 2010, 621 SCRA 646 — Cited for the elements of robbery with homicide and the rule that intent to rob must precede the taking of human life.
• People vs. De Jesus, 473 Phil. 405 (2004) — Cited with Baron for the elements of robbery with homicide.
• People vs. Dela Cruz, 575 SCRA 412 (2008) — Cited for the rule that the killing in robbery with homicide may occur before, during, or after the robbery.
• People vs. Musa, G.R. No. 170472, July 3, 2009, 591 SCRA 619 — Cited for the timing of the killing in robbery with homicide and for the award of moral damages.
• Salvador vs. People, G.R. No. 164266, July 23, 2008, 559 SCRA 461 — Cited for the requisites of circumstantial evidence and the unbroken-chain standard.
• People vs. Escote, Jr., 448 Phil. 749 (2003) — Cited for the rule that all principals in the robbery are liable for robbery with homicide even if they did not actually kill, unless they tried to prevent the killing.
• People vs. Suela, 424 Phil. 196 (2002) — Cited for the admissibility of an oral confession made to a private person who is not a police officer.
• People vs. Mateo, G.R. Nos. 147678-87, July 7, 2004, 433 SCRA 640 — Cited as the basis for the SC’s referral of the case to the CA for intermediate review.

• Article 294, Revised Penal Code, as amended by Republic Act No. 7659 — Punishes robbery with homicide by reclusion perpetua to death; applied as the special complex crime for which Uy was convicted.
• Article 63, Revised Penal Code — Provides that when the law prescribes two indivisible penalties and the crime is neither attended by mitigating nor aggravating circumstances, the lesser penalty shall be imposed; applied to impose reclusion perpetua instead of death.
• Sections 8 and 9, Rule 110, 2000 Revised Rules on Criminal Procedure — Require aggravating circumstances to be alleged in the information; applied to disregard nocturnity and treachery because they were not alleged.
• Section 4, Rule 133, Revised Rules of Court — Sets the requisites for circumstantial evidence; applied to sustain conviction based on an unbroken chain of circumstances.
• Article III, Sections 12(1) and (3), 1987 Constitution — Protect persons under custodial investigation; held not applicable to Uy’s oral confession to Eduardo because he was not under custodial investigation.
• Rule 130, Section 33, Rules of Court — Allows the declaration of an accused acknowledging guilt to be given in evidence against him; applied to admit Eduardo’s testimony on Uy’s oral confession.