Case Summary (G.R. No. 146875)
Charges and Arrest
On August 8, 1986, Jalon and Magsalos were charged with murder in Criminal Case No. 6902 in the Regional Trial Court of Misamis Oriental, Branch 21. Jalon was arrested on October 27, 1986, and was arraigned on November 26, 1986, entering a plea of not guilty. Magsalos was arrested later and never formally arraigned due to health issues; charges against Magsalos were eventually dismissed on December 5, 1988.
Events of the Crime
The murder occurred around 10 PM on May 28, 1986, when Pelarito Abujan was on his way to a dance hall. He was shot multiple times, resulting in fatal injuries to his head and neck. Witnesses reported hearing gunfire and testified that Jalon was seen fleeing the scene after the shots were fired. Both Allan Gamlot and Eddie Apus provided varying accounts of the events leading to the shooting and the identities of those involved.
Defense Strategy
Jalon maintained his innocence through an alibi, asserting he was at his employer's house in Carmen, about twelve kilometers from Baikingon, at the time of the murder. His employer corroborated his alibi, stating Jalon had been working as a watchman that night. Jalon indicated that it would have been physically impossible to travel the distance back to the crime scene within the time frame of the murder.
Trial Court Proceedings
The trial court, on May 31, 1989, found Jalon guilty of murder based on circumstantial evidence and sentenced him to life imprisonment along with accessory penalties and ordered him to pay damages to the victim's heirs. The court held that the testimonies of the prosecution witnesses were credible and consistent, despite the lack of direct eyewitness accounts.
Appellate Review
On appeal, Jalon raised two key errors: (1) the court's identification of him as the perpetrator despite the defense testimony, and (2) the sufficiency of circumstantial evidence leading to his conviction. The appellate court emphasized that the findings of the trial court typically hold significant weight unless there is a lack of evidentiary support or if material facts were overlooked.
Examination of Prosecution Evidence
The appellate court analyzed the testimonies of Gamlot and Apus and found substantial inconsistencies. For example, Gamlot's testimony regarding the timeline of events conflicted with established facts and suggested a delay that enabled the alleged perpetrators to flee without being pursued. Apus' testimony also exhibited contradictions, particularly regarding the circumstances under which he witnessed the defendants flee.
Circumstantial Evidence Standards
The court reiterated that circumstantial evidence must cons
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Case Background
- Accused-appellant Deogracias Jalon was charged with murder on August 8, 1986, alongside co-accused Tadios Magsalos in Criminal Case No. 6902 at the Regional Trial Court of Misamis Oriental, Branch 21, Cagayan de Oro City.
- The charge stemmed from the incident that occurred on May 28, 1986, where Pelarito Abujan was allegedly shot and killed with treachery and evident premeditation by the accused, who were armed with firearms.
- The prosecution claimed that Jalon and Magsalos conspired to kill Abujan, inflicting fatal wounds on his head and neck.
Arrest and Arraignment
- Deogracias Jalon was arrested on October 27, 1986, and arraigned on November 26, 1986, entering a plea of not guilty with the assistance of counsel.
- Co-accused Tadios Magsalos was arrested later on June 22, 1988, but never formally arraigned due to health issues, leading to the dismissal of charges against him on December 5, 1988.
Incident Description
- The murder occurred in Barangay Baikingon, Cagayan de Oro City, with the victim shot while on his way to a dance hall.
- Prosecution witnesses included Allan Gamlot and Eddie Apus, who provided differing accounts of the circumstances and companions present during the shooting.
- Gamlot claimed he was with Alexander Abujan when they heard shots, while Apus indicated that he was with multiple companions including Gamlot.
Testimonies and Evidence
- Witnesses reported hearing three shots, with Abujan falling after the third shot. They later cl