**Facts:**
On the evening of April 15, 1991, Onofre Malaki was attending to his store when Jose Encarnacion Malimit, wielding a bolo, emerged from the store, leaving Malaki fatally wounded. Witnesses Florencio Rondon and Edilberto Batin identified Malimit as the assailant. Malaki’s store appeared ransacked, and his wallet was missing. Subsequent investigations led to Malimit’s arrest, where he led police to the hidden wallet. Charged with robbery with homicide, Malimit was convicted and sentenced to reclusion perpetua. His appeal raised doubts about witness credibility, alleged constitutional rights violations concerning evidence admission, and contended that the prosecution failed to prove guilt beyond a reasonable doubt.
**Issues:**
1. Whether the delay in witness identification of the accused affected the credibility of testimony.
2. Whether the wallet’s admissibility as evidence violated the accused’s constitutional rights.
3. Whether the circumstantial evidence presented was sufficient to convict the accused beyond reasonable doubt.
**Court’s Decision:**
1. The Supreme Court dismissed the concerns about the delayed identification, emphasizing the immediate actions taken by witnesses to report the crime. The Court noted that the delay in executing affidavits does not inherently discredit witness testimonies.
2. In regards to the wallet and its contents, the Court ruled that the right against self-incrimination does not extend to the exclusion of object evidence obtained from the accused. Moreover, any procedural lapses during custodial investigations were irrelevant to the admissibility of the wallet as material evidence.
3. The Court affirmed the sufficiency of circumstantial evidence to convict Malimit, outlining the unbroken chain of events that pointed unmistakably to his guilt. The combined weight of eyewitness accounts, recovery of the stolen wallet, and Malimit’s behavior post-crime (including his flight) supported the verdict.
**Doctrine:**
– The right against self-incrimination does not protect an accused from the use of physical evidence obtained from them.
– Circumstantial evidence, when forming an unbroken chain leading to a fair and reasonable conclusion of guilt, is sufficient for conviction beyond a reasonable doubt.
**Class Notes:**
– **Credibility of Witnesses:** The credibility can be upheld even if there’s a delay in witness identification or reporting, as long as the delay is reasonably explained or justified.
– **Right Against Self-Incrimination:** Pertains to testimonial evidence and does not extend to object evidence obtained from the accused.
– **Circumstantial Evidence:** Requires (a) more than one circumstance, (b) facts from which inferences are derived must be proven, and (c) all circumstances must lead to a conviction beyond a reasonable doubt.
– **Flight and Behavior Post-Crime:** An accused’s flight and behavior post-crime can contribute to the circumstantial evidence indicating guilt.
**Historical Background:**
This case reflects the Philippine Supreme Court’s approach to handling issues of delayed witness identification and the admissibility of evidence obtained during police investigations. It underscores the balance between procedural safeguards for the accused and the societal interest in prosecuting criminal activities. Furthermore, it highlights the judicial scrutiny applied in evaluating the sufficiency of both direct and circumstantial evidence in criminal proceedings.
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