The Supreme Court (SC) has stressed that circumstantial evidence may sustain a criminal conviction only when the proven circumstances, taken together, establish guilt beyond reasonable doubt and exclude any reasonable hypothesis of innocence.
In a decision penned by Associate Justice Alfredo Benjamin S. Caguioa, the SC Third Division applied the standard in acquitting a man charged with violating the election liquor ban, finding that the prosecution’s circumstantial evidence was insufficient to prove his guilt beyond reasonable doubt.
“A conviction may rest upon circumstantial testimony alone, but the facts and circumstances must be such as are absolutely incompatible upon any reasonable hypothesis with the innocence of the accused,” the Court said, quoting established jurisprudence.
Strict standards for circumstantial evidence
The SC explained that circumstantial evidence can support a conviction only when there is more than one circumstance, the facts from which the inferences are drawn are proven, and their combination establishes guilt beyond reasonable doubt, with the circumstances incompatible with any reasonable hypothesis of innocence.
While circumstantial evidence is not inferior to direct evidence, the Court said their equal probative standing does not dispense with the stringent safeguards governing its appreciation.
The SC further stressed that this parity does not authorize the abandonment of objective proof when it is plainly obtainable, saying the use of circumstantial evidence in such circumstances cannot be justified by “convenience or inadequacy of law enforcement.”
“Where available means of verification is inexplicably disregarded and the prosecution relies instead on tenuous inferences,” the Court said, treating such evidence as sufficient would “transform a rule born of necessity into a refuge for investigative shortcomings.”
Case background
The case stemmed from the arrest of Mcgill Esquillo Omandam in Iligan City on May 12, 2019, a day before the national and local elections, after barangay personnel found him appearing intoxicated and saw two empty liquor bottles in the area. Witnesses said Omandam smelled of alcohol, had slurred speech and moved groggily, but no one saw him drinking.
The Regional Trial Court convicted Omandam and co-accused Samson Natuil Tapere and sentenced each to one year in prison. On appeal, the Court of Appeals (CA) acquitted Tapere but upheld Omandam’s conviction based on circumstantial evidence.
Omandam challenged his conviction before the SC, arguing that no prosecution witness saw him drinking and that authorities conducted no breath analyzer or chemical test to establish alcohol consumption. The SC reexamined the facts after finding that the lower courts relied largely on conjectural inferences and that the CA failed to consider relevant and undisputed facts that could have affected the outcome.
The SC noted that the offense required proof that Omandam consumed intoxicating liquor during the prohibited period. However, authorities conducted no field sobriety, breath analyzer or confirmatory chemical test, while the recovered liquor bottles were not subjected to forensic examination that could have linked them to the accused.
Finding that the evidence amounted to a “fragile web of assumptions unsupported by objective verification,” the SC reversed the CA rulings and acquitted Omandam for failure to prove his guilt beyond reasonable doubt.
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