G.R. No. 187725 - Jesalva vs. People

On September 11, 1992, the Chief of Police of Sorsogon filed a complaint for frustrated murder against petitioner Benjamin Jesalva.
On September 15, 1992, the complaint was amended to murder when victim Leticia Aldemo died on September 14.
On December 18, 1992, the Municipal Trial Court granted petitioner bail.
On January 11, 1993, the MTC recommended the filing of murder and transmitted the records to the Provincial Prosecutor.
On January 26, 1993, an Information for murder was filed in the RTC.
On March 1, 1993, petitioner pleaded not guilty at arraignment.

Gloria Haboc testified that on the evening of September 8, 1992, she, Leticia, petitioner and others played mahjong, then rode in petitioner’s panel truck to Bistro Christina, drank until 11:30 p.m., and later reboarded the truck; petitioner dropped off companions but drove toward 6th Street instead of the shorter 7th Street where Leticia lived.
At about 12:20 a.m., SPO1 Edgardo Mendoza patrolling St. Rafael Subdivision saw petitioner in his vehicle; when called, petitioner accelerated and fled toward town proper.
Noel Olbes discovered Leticia naked from the waist down and bleeding on the highway; fearing implication, he moved her to a shed at Hazelwood about ten meters away.
Police later found Leticia at Hazelwood at about 2:15 a.m. in a comatose state with multiple injuries; Olbes was initially detained but released when evidence pointed to petitioner as the last person seen with the victim.
Around 1:00 p.m. on September 9, petitioner and his cousin, Fiscal Jose Jayona, “surrendered” and told SPO4 Desder that Leticia jumped from his vehicle at St. Rafael Subdivision.
An ocular inspection at the pointed site revealed fresh bloodstains.
Dr. Antonio Dioneda Jr. and Dr. Wilhelmino Abrantes described Leticia’s injuries—multiple contusions, punctured wounds, skull fracture—consistent with violent assault and possible fall.

Petitioner testified, denying any intent or act of killing.
Eduardo de Vera claimed he saw Noel Olbes assisting a wounded woman, not petitioner; Olbes later admitted moving Leticia to the shed.
SPO1 Eduardo Balaoro and Olbes testified on their version of the police investigation and Olbes’s actions.
On February 21, 1994, defense filed a demurrer to evidence, denied July 8, 1994; motion for reconsideration and judge inhibition prompted re-raffle to RTC Branch 52.
On November 18, 1997, the RTC convicted petitioner of homicide (not murder) and sentenced him under the Indeterminate Sentence Law; petitioner appealed.
On October 17, 2008, the Court of Appeals affirmed the conviction with modification of penalty; it denied reconsideration on April 7, 2009.

Whether the conviction based solely on circumstantial evidence complied with the rule that all essential facts must be consistent with the hypothesis of guilt and proved beyond reasonable doubt.
Whether petitioner’s statements at the police station were admissible, or were made during a custodial investigation in violation of his right to remain silent.