G.R. No. 68969 - People vs. Hassan y Ayun

The case involves a pauper’s appeal from the decision of the Regional Trial Court (RTC) of Zamboanga City, Branch XIII, rendered on January 25, 1984.
The petitioner is the People of the Philippines while the respondent is Usman Hassan y Ayun.
The trial court had found the accused guilty beyond reasonable doubt as the principal in the crime of murder and imposed reclusion perpetua, along with accessory penalties and an indemnity to the heirs of the deceased.
The decision was ultimately reversed on appeal, resulting in the acquittal of the accused.

The victim, Ramon Pichel, Jr. y Uro, aged 24, was a single manager in his father’s sand and gravel business and was killed on July 23, 1981 through a stabbing.
The accused, Usman Hassan, was described as a 15-year-old pushcart cargador, characterized by his poverty, marginalization, and lack of formal education.
Usman’s background was marked by displacement and poverty, having been forced to move several times due to local conflicts and internal strife.
His birth was not formally registered because of the local customs of the Samal tribe, to which he belongs.

The primary evidence against the accused consisted of the testimony of a single eyewitness, Jose Samson, a 24-year-old who was employed by the victim’s family at the sand and gravel business.

Samson testified that he saw Ramon Pichel, Jr. with the accused and later witnessed an unidentified assailant stabbing the victim as he was seated on his motorcycle.
His account described the assailant as wearing a white, short-sleeved t-shirt and maong pants, and noted that the stabbing occurred “only once.”

The police investigation, led by Police Corporal Rogelio Carpio of the Homicide and Arson Section, involved an identification procedure wherein the accused was confronted with Samson at the La Merced Funeral Homes.

Although initially indicated as a confrontation, Carpio later mentioned that it was conducted as a “police line-up,” creating discrepancies in the method of identification.
The procedure was criticized for being suggestive and conducted in an environment that could compromise the reliability of the eyewitness identification.

A sworn statement by eyewitness Samson taken within a couple of days after the crime.
A “Case Report” by Corporal Carpio which essentially mirrored Samson’s sworn statement.
The confiscation of a knife from the accused during arrest, which measured approximately seven inches but was not adequately subjected to forensic testing.

The investigation was noted to be superficial, with certain potential witnesses (e.g., a fruit vendor present at the scene) not being investigated or questioned.

The testimony of the sole eyewitness was found to be inconsistent and weak when subjected to cross-examination.
The analyst testimony of the medico-legal officer contradicted key elements of the eyewitness account by indicating two stab wounds instead of one and asserting that the fatal wound was inflicted while the victim was facing the assailant.
The police investigator’s handling of identification – by presenting the accused singly to Samson in a confrontation rather than a formal lineup – was deemed improper and suggestive, likely influencing the witness’s testimony.
Procedural lapses included the hastily taken and sworn eyewitness statement and the failure to explore other leads such as examining the knife for forensic evidence like blood traces.

The absence of a clearly established motive on the part of the accused was noted, particularly as the victim was a complete stranger.
Usman Hassan’s alibi, which stated that he was at a nearby public area waiting for transportation, was given scant consideration and left largely unexamined by the trial court.
Challenges were also raised regarding the accused’s age. Testimony by his mother and a later dental assessment provided a broad age range (14 to 21 years), though the court ultimately observed that he was about 18 years old at the time of the incident.
The overall background of the accused emphasized his status as a marginalized individual, highlighting concerns about the fairness of the investigative process and the application of justice given his socio-economic disadvantage.

Whether the testimony of the lone eyewitness and the police evidence were sufficient to establish the guilt of the accused beyond reasonable doubt.
Whether the inconsistencies in witness statements and forensic testimony undermined the prosecution’s case.

Whether the police-conducted identification (confrontation versus lineup) of the accused was proper and free from suggestiveness.
Whether the identification process violated the accused’s constitutional right to due process and counsel.

Whether the police investigation was thorough and properly conducted, particularly regarding the handling of forensic evidence (e.g., the untested knife) and interviewing of potential material witnesses.
Whether the shortcomings in the investigation contributed to the prejudicial presentation of evidence against the accused.

Whether the failure to conclusively establish the accused’s age (potentially a minor) should have been given more weight as a mitigating circumstance in assessing criminal liability.
Whether the trial court’s procedural approach and clarifying questions exhibited fairness and sensitivity to the accused’s vulnerable status.