Case Summary (G.R. No. 236827)
Proceedings and Verdict
The legal proceedings began with a criminal complaint filed on February 9, 1965, leading to an information charge for murder filed on September 30, 1965, subsequently amended to include Bitel Abboc. On September 19, 1969, the trial court found all three defendants guilty of murder, sentencing them to reclusion perpetua, ordering them to indemnify the heirs of Lucagan Banig in the sum of P6,000, and to pay the costs.
Testimonies and Evidence Presented
The trial court based its decision primarily on the testimonies of Dayapan Banig and Marcos Banig, siblings of the victim. Dayapan recounted events leading to the shooting, including the arrival of the accused at her home prior to the incident, followed by gunshots and her brother's dying declaration that implicated the Abboc defendants. Additionally, Bantes Saluquem, a Sanitary Inspector, confirmed through an exploratory examination that Lucagan Banig had sustained several gunshot wounds consistent with a rifle.
Rejection of Defense
The defense presented an alibi claiming that Ayaman and Bitel Abboc were attending to a sick grandfather during the timeframe of the murder. The trial court dismissed this defense due to the close proximity and timeframe that would have allowed the accused to be at the crime scene. Furthermore, the alibi for Bersamin Abboc was undermined by inconsistencies in testimony regarding his whereabouts, including alterations in police records that suggested fabrication.
Appellate Review and Standards of Credibility
In reviewing the case, the appellate court affirmed the trial court's judgment, emphasizing that credibility assessments by the trial court are given significant deference unless a clear error or oversight emerges from the records. The court found no such grounds for disturbing the trial court's findings. The appellate court also rejected the appellants' speculative arguments regarding the testimonies of the prosecution witnesses, highlighting that those assertions
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Case Information
- Court: Supreme Court of the Philippines
- Decision Date: September 14, 1973
- G.R. No.: L-28327
- Division: First Division
- Judgment: Affirmation of lower court's decision
Background of the Case
- The appeal arises from a guilty verdict rendered against the accused-appellants, Ayaman Abboc, Bitel Abboc, and Bersamin (Benjamin) Abboc for the crime of murder.
- The case originated from a criminal complaint filed on February 9, 1965, by the chief of police of Sallapadan, Abra.
- An information for murder was filed on September 30, 1965, and later amended on March 8, 1966.
- The trial court rendered its judgment on September 19, 1969, sentencing each accused to reclusion perpetua and requiring them to indemnify the heirs of the victim, Lucagan Banig, in the amount of P6,000.00.
Facts of the Case
- The victim, Lucagan Banig, was shot on January 27, 1965.
- Witnesses Dayapan Banig (sister of the victim) and Marcos Banig (brother of the victim) testified against the accused.
- Dayapan Banig stated that the accused came to her house asking for Lucagan before the shooting occurred.
- After hearing gunshots, she found Lucagan wounded, who identified Ayaman and Benjamin Abboc as his assailants, with Bitel Abboc being the sho