Facts:

The case involves Teotimo Alegarme, the defendant-appellant, who was convicted of murder by the Court of First Instance of Zamboanga del Sur. The incident occurred on January 19, 1961, shortly after 11:00 p.m., in the barrio of Dagohoy, Dumalinao, Zamboanga del Sur. The victim, Basilio Alegarme, was shot while walking home after attending religious services during a town fiesta. Witness Estelita Canencia testified that she saw Teotimo and his brother Adolfo Alegarme at the scene, with Teotimo aiming a gun at Basilio and Adolfo holding a bolo. After the gun was fired, Basilio fell to the ground, and the two defendants allegedly approached the body to check if he was still alive. The prosecution's case relied heavily on Estelita's testimony and an alleged confession from Teotimo, which he later repudiated, claiming it was obtained under duress. The trial court found Estelita's testimony credible despite inconsistencies, while the defense presented an alibi, assertin...

Facts:

Background of the Case:

• Teotimo Alegarme and Adolfo Alegarme were charged with the murder of their brother, Basilio Alegarme, in Zamboanga del Sur on January 19, 1961.
• Basilio was shot while walking home after attending religious services. He died due to hemorrhage caused by the gunshot wound.

Prosecution’s Evidence:

1. Testimony of Estelita Canencia:

   • Estelita claimed she was with Basilio and others walking home when she saw Teotimo and Adolfo hiding in a banana grove.
   • She testified that Teotimo aimed a gun at Basilio, fired, and killed him. Adolfo held a bolo.
   • She alleged that Teotimo confirmed Basilio was dead, and both fled the scene.
   • The trial court found her testimony unreliable due to inconsistencies, hesitation, and her relationship with Captain Alegarme, who had a land conflict with the defendants.

2. Alleged Confession (Exhibit D):

   • Teotimo allegedly confessed to the crime, but he claimed the confession was coerced through physical abuse by the Chief of Police, Eutiquio Codilla.
   • The Justice of the Peace testified that Teotimo refused to sign the confession in his presence, casting doubt on its voluntariness.

Defense’s Evidence:

• Teotimo and Adolfo presented an alibi, stating they were at Adolfo’s house caring for a sick child on the night of the incident.
• They denied involvement in the crime and claimed the confession was obtained under duress.

Trial Court’s Findings:

• The trial court convicted Teotimo based on his alleged confession and circumstantial evidence, including a land conflict between the brothers and the recovery of a shotgun allegedly used in the crime.
• Adolfo was acquitted due to insufficient evidence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Voluntariness of Confessions:

   • Confessions must be made freely and voluntarily, without any form of coercion or duress. The circumstances surrounding Teotimo’s alleged confession raised serious doubts about its voluntariness, rendering it inadmissible as evidence.

2. Credibility of Witnesses:

   • Witness testimony must be clear, consistent, and free from bias. Estelita Canencia’s testimony was marred by inconsistencies, hesitation, and her relationship with Captain Alegarme, making it unreliable.

3. Burden of Proof:

   • In criminal cases, the prosecution must prove the defendant’s guilt beyond reasonable doubt. The circumstantial evidence presented was insufficient to meet this standard, especially in light of the acquittal of Adolfo based on the same evidence.

4. Presumption of Innocence:

   • The accused is presumed innocent until proven guilty. The prosecution’s failure to provide conclusive evidence warranted Teotimo’s acquittal.