G.R. No. L-31135 - Director of Bureau of Telecommunications vs. Aligaen

On December 16, 1977, in the Municipality of Lumban, Laguna, a shooting occurred during a session of the Sangguniang Bayan at a canteen near the municipal building.
The victim, Andres Manambit Sr., a Barangay Captain and President of the Association of Barangay Captains, was fatally shot.
The information charged accused Mario Ablao, along with others (Alberto Almario, Zenon Samonte, Hector Samonte, and Bruno Ablao), though only Mario Ablao was ultimately implicated after others were acquitted.

Narrated that around 5:00 PM, while on duty in Lumban, he witnessed Mario Ablao emerging from the canteen carrying a .45 caliber pistol immediately after gunfire was reported.
He observed Ablao running toward Caliraya mountain and, after a failed attempt to chase him, discovered the dead body of Andres Manambit Sr. with a gunshot wound to the right side of the neck.
Conducted an investigation that included collecting witness statements and obtaining an autopsy.

Performed the autopsy on the body of the victim, establishing that the fatal wound was a gunshot to the head which resulted in acute, profuse hemorrhage.
Described the wound’s characteristics that correlated with the use of a .45 caliber firearm, including specifics regarding the wound’s location and the bullet’s trajectory.

Abraham Abayari testified that he saw Lt. Gapas being fired upon by Ablao as the incident unfolded and described the chaotic aftermath.
Felix de Ramos testified that near the time of the shooting, he witnessed the victim already lying dead after hearing multiple shots, with police in pursuit of a fleeing individual.
Additional testimonies, including that of technical sergeant Catalino Garcia, provided circumstantial details to corroborate the sequence of events.

Mario Ablao testified that he was present in the municipal building at the behest of his brother, Mayor Bruno Ablao, and subsequently proceeded to the canteen upon learning the mayor was absent.
He claimed that after the first shot, his brother handed him a gun and instructed him to flee.
Ablao maintained that he merely obeyed his brother’s direction, and that he did not actually shoot Andres Manambit Sr. but rather, was in a state of confusion and fear, which caused him to hide.
His narrative sought to shift the blame by insinuating that his brother, who later died during the trial, might have been the actual gunman.

Ablao was the first person seen fleeing the scene, carrying a .45 caliber pistol immediately after the shooting, in a manner inconsistent with the behavior of an innocent bystander in shock.
The physical evidence, including the autopsy report, confirmed that the fatal injury was inflicted by a bullet consistent with the weapon Ablao possessed.
The delayed voluntary surrender—after 2 1/2 years—undercut his claim of merely hiding without guilt.
The circumstances indicated that no other person, including the mayor, was in a position to commit the crime, as none were seen in immediate proximity with a weapon at the time of the fatal shot.

The Regional Trial Court of Laguna, Branch 26, convicted Mario Ablao of murder based on circumstantial evidence, finding him guilty beyond reasonable doubt.
The trial decision required the imposition of the death penalty initially, along with an award of indemnity to the heirs of the victim and costs.
Appellate issues emerged concerning the sufficiency of evidence, the qualification of the crime as murder based on treachery or premeditation, and the propriety of the prefatory statements highlighting political vendetta and additional suspect involvement.

Whether the trial court erred in finding that accused-appellant Mario Ablao was the one who shot the deceased Andres Manambit Sr.

Consideration of the circumstantial evidence directly linking Ablao to the shooting.
Analysis of the credibility and consistency of the eyewitness testimonies.

Whether the evidence sufficed to prove that the crime committed was murder, particularly regarding the presence of qualifying circumstances such as treachery or evident premeditation.

Examination of whether the details of the fatal gunshot wound and the circumstances of the shooting met the requirements for murder as distinct from homicide.

Whether the imposition of the death penalty on the accused-appellant was appropriate given the evidence presented.

Discussion on the appropriateness of the penalty in light of the circumstantial nature of the evidence.

Whether the trial court erred in its prefatory statement regarding the series of violence and political vendetta in Lumban, Laguna, which included mentioning that the accused-appellant was also a suspect in another killing (that of Judge Sobejana and his son).

Consideration of whether such statements unfairly prejudiced the accused by conflating separate incidents.

Whether the overall circumstantial evidence collectively established the guilt of the accused beyond a reasonable doubt.