Facts:

The case involves Benjamin Jesalva (petitioner), accused of homicide against Leticia Aldemo (victim). On September 11, 1992, the Chief of Police of Sorsogon filed a criminal complaint for frustrated murder against Jesalva, which was amended on September 15, 1992, to murder after Leticia died on September 14, 1992. The Municipal Trial Court (MTC) granted Jesalva bail on December 18, 1992, and on January 26, 1993, an Information for murder was officially filed against him. The arraignment took place on March 1, 1993, where he pleaded not guilty.

The prosecution's evidence indicated that on the night of the incident, Jesalva, along with several individuals, played mahjong before heading to a restaurant for drinks. Afterward, Jesalva was last seen driving Leticia, who expressed her desire to just be friends due to her marital status, home. However, he drove in the opposite direction and was later seen speeding away from the police who tried to stop him.

At around 12:30 AM on S

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Facts:

Procedural Background

• Petitioner Benjamin Jesalva, also known as Ben Sabaw, was charged and subsequently convicted for the crime of homicide in connection with the death of Leticia Aldemo.
• The case traversed through multiple levels of adjudication:
• The Regional Trial Court (RTC) of Sorsogon rendered a decision on November 18, 1997, convicting Jesalva based on circumstantial evidence.
• The Court of Appeals (CA) affirmed the RTC decision on October 17, 2008 with modifications regarding the penalty.
• Petitioner subsequently filed a Petition for Review on Certiorari before the Supreme Court.

Chronology and Nature of the Offense

• Initial Complaints and Charges
• On September 11, 1992, the Chief of Police of Sorsogon filed a criminal complaint for Frustrated Murder against the petitioner.
• On September 15, 1992, the complaint was amended to charge the petitioner with Murder, following the victim’s death on September 14, 1992.
• Pre-Trial and Trial Proceedings
• The Municipal Trial Court (MTC) granted bail to petitioner on December 18, 1992.
• An Information charging petitioner with Murder was filed on January 26, 1993, after the MTC recommended the filing of the complaint.
• During arraignment on March 1, 1993, petitioner pleaded not guilty, leading to a full trial on the merits.

Testimonies and Versions Presented

• Version of the Prosecution
• Circumstantial evidence was presented by the prosecution, relying primarily on the sequence of events and testimonies from several witnesses.
• Key testimonies described the following events:
• On September 8, 1992, petitioner was seen playing mahjong with the victim Leticia Aldemo, Gloria Haboc, and other individuals at Nena’s place.

ii. After leaving the establishment around 10 p.m., the group boarded petitioner’s Isuzu panel. iii. The group had dinner at Bistro Christina and then departed, with petitioner driving Leticia and another witness, Gloria Haboc, at different points. iv. At approximately 12:20 a.m. on September 9, 1992, police observed petitioner on his vehicle at St. Rafael Subdivision. When addressed by a police officer, he did not respond and drove away toward Sorsogon town proper.

Pre-Trial Motions and Subsequent Developments

• The defense moved for a demurrer to evidence, which was filed on February 21, 1994 and later denied by the RTC.
• A motion for reconsideration and request for the inhibition of the presiding judge was also filed; these actions led to the voluntary inhibition of one judge and the re-raffling of the case to another branch.

Post-Conviction Arguments

• On appeal before the CA, petitioner argued:
• That the circumstantial evidence was insufficient and inconsistent with the hypothesis of guilt.
• That the statements made at the police station were inadmissible as they were made while he was under what could have been construed as custodial investigation.
• The CA, while modifying the penalty, found that the chain of circumstantial evidence was sufficient to link petitioner to the crime.

Issue:

Sufficiency and Coherence of Circumstantial Evidence

• Whether the circumstantial evidence, when viewed as an unbroken chain, was enough to convict petitioner of homicide beyond reasonable doubt.
• Whether the evidentiary requirements for a conviction based on circumstantial proof were met, specifically:
• The presence of multiple circumstances.
• Evidentiary establishment of the facts from which inferences were derived.
• The combination of facts pointing uniquely to the petitioner as the perpetrator.

Admissibility of Petitioner’s Statement

• Whether the statements made by petitioner at the police station were admissible as evidence despite allegations of custodial investigation.
• Whether petitioner’s voluntary statement, given in the presence of Fiscal Jayona and not elicited by coercive police questioning, violated his constitutional rights.

Attribution of Responsibility

• Whether the identification of petitioner as the last person seen with the victim was adequate to exclude other potential suspects, such as Noel Olbes.
• Whether the discrepancies in the accounts regarding the movements of petitioner sufficiently undermined the prosecution’s case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)