G.R. No. 177775 - People vs. Dizon

On December 25, 2001, the lifeless body of Jeto Santos was found floating in a creek in Sangbay, Nagtipunan, Quirino.
The location where the victim was discovered pointed to the proximity of a videoke bar and a residential area, establishing the crime scene near the bar.

Eyewitness accounts and observations identified Rodel Dizon, Virgilio Pascua, and Isaias Dizon as the last persons seen with the victim.
The police immediately arrested the three individuals; however, the Office of the Provincial Prosecutor, by resolution dated January 29, 2002, found probable cause against only Isaias Dizon, charging him with murder.

On the evening of December 24, 2001, the victim entered a videoke bar and began dancing to the music.
Around 10:00 to 11:00 in the evening, while the victim had gone outside to relieve himself near the bar, Isaias Dizon allegedly exited the bar accompanied by Rodel Dizon and Virgilio Pascua.
At the stone-littered edge of a creek, appellant Isaias Dizon is accused of picking up a fist-sized stone and striking Jeto Santos on the head, causing the victim to fall.
A subsequent attempt involved appellant picking up another, longer stone intended for a further blow, but the attack was interrupted by Rodel Dizon who prevented the second blow; however, appellant then continued his assault by using the same stone.

Rodel Dizon, whose grandparent was related to appellant, testified that he witnessed the assault which involved appellant hitting the victim in the head with stones, describing both the size and impact of the stones.
The testimony of Dr. Perla Olay corroborated the account by noting the severity of the head wounds sustained by the victim, including multiple lacerations and exposure of brain tissue.
Appellant’s identity was positively asserted by Rodel Dizon despite the familial relation, leading the trial court to credit his identification absent a demonstration of ulterior motive.

Appellant Isaias Dizon denied the charge of murder.
He admitted to being at the videoke bar with Rodel and Pascua but claimed he left the establishment at approximately 8:45 in the evening at the behest of his wife, Mary Jane, thereby establishing an alibi.
Mary Jane’s testimony provided additional details: she heard Rodel at around 11:00 in the evening knocking on a neighbor's door, stating phrases such as “Uncle, uncle, please open up because I have killed,” and later approaching their house seeking money, though without identifying the victim explicitly.

The Regional Trial Court (RTC) of Maddela, Quirino, in its decision dated January 10, 2005, convicted appellant Isaias Dizon of murder.
The RTC sentenced him to reclusion perpetua and ordered the payment of various damages: a civil indemnity, moral damages, actual expenses, and temperate damages, while also crediting his preventive imprisonment time under Article 29 of the Revised Penal Code.

Appellant challenged the RTC decision on two main points: (a) his conviction beyond reasonable doubt, and (b) the finding of treachery as a qualifying circumstance in the commission of murder.
The Court of Appeals, in its Decision of October 31, 2006, affirmed the RTC decision in toto with modifications in the civil awards, reducing the civil indemnity from ₱75,000 to ₱50,000, deleting temperate damages, and awarding exemplary damages of ₱25,000.

Whether the evidence, including eyewitness testimony by Rodel Dizon and medical findings by Dr. Perla Olay, was sufficient to prove beyond reasonable doubt that appellant Isaias Dizon committed murder.
The credibility and reliability of the eyewitness identification by a relative, considering potential bias or ill motive.

Whether the manner of appellant’s execution of the crime—specifically, his deliberate and sustained attack with stones against a defenseless victim—fulfilled the requisites of treachery as a qualifying circumstance for murder.
If treachery is established, whether the evidentiary basis is strong enough to justify its inclusion as an aggravating circumstance.

Whether appellant’s alibi, asserting that he left the bar at 8:45 in the evening and was not present at the locus criminis at the time of the commission of the crime, is credible and corroborated by evidence.
The proximity of the videoke bar to his residence and the implications of this on his ability to be present at the scene.

Whether the adjustments in the civil aspect—specifically the reduction of civil indemnity to ₱50,000, deletion of temperate damages, and award of exemplary damages—are justified under prevailing jurisprudence and the facts of the case.