Decision
8
G.R. No. 224469
In practice, there is proof beyond a reasonable doubt where the judge
can conclude: "All the above, as established during trial, lead to no other
conclusion than the commission of the crime as prescribed in the law." 29 It
has been explained:
With respect to those of a contrary view, it is difficult to think of a more
accurate statement than that which defines reasonable doubt as a doubt
for which one can give a reason, so long as the reason given is logically
connected to the evidence. An inability to give such a reason for the
doubt one entertains is the first and most obvious indication that the
doubt held may not be reasonable. In this respect, I agree with the United
States Court of Appeals, District of Columbia Circuit, in US v. Dale, 991
F.2d 819 (1993) at p.853: "The instruction ... fairly convey[s] that the
requisite doubt must be 'based on reason' as distinguished from fancy,
whim or conjecture."
You will note that the Crown must establish the accused's guilt
beyond a "reasonable doubt", not 'beyond "any doubt". A
reasonable doubt is exactly what it says -a doubt based on
reason- on the logical processes of the mind. It is not a
fanciful or speculative doubt, nor is it a doubt based upon
sympathy or prejudice. It is the sort of doubt which, if you
ask yourself "why do I doubt?" -you can assign a logical
reason by way of an answer.
A logical reason in this context means a reason connected
either to the evidence itself, including any conflict you may
find exists after considering the evidence as a whole, or to an
absence of evidence which in the circumstances of this case
you believe is essential to a conviction.
You must not base your doubt on the proposition that
nothing is certain or impossible or that anything is
possible. You are not entitled to set up a standard of
absolute certainty and to say that the evidence does not
measure up to that standard. In many things it is impossible to
prove absolute certainty. 30
First Issue: Petitioners are IrayaMangyan IPs who are a publicly
known ICC inhabiting areas
within Oriental Mindoro.
IPs in the Philippines inhabit the interiors and mountains of Luzon,
Mindoro, Negros, Samar, Leyte, Palawan, Mindanao, and Sulu group of
islands. 31 In Cruz v. Secretary of Natural Resources, 32 the Court recognized
the following ICCs residing in Region IV: Dumagats of Aurora, Rizal;
29
30
31
32
Dinamlingv. People, 761 Phil. 356,374 (2015).
R. v. Lifchus, 1996 CanLII 6631 (MB CA), <http://canlii.ca/t/lnpkc>, retrieved on 2020-08-25.
See J. Puno's Separate Opinion (Cruz v. Secretary of Environment and Natural Resources, (Resolution,
Per Curiam, En Banc), 400 Phil. 904, 947 (2000).
Id.