Case Summary (G.R. No. 157866)
Charges and Court Proceedings
An information was filed against Sia on September 22, 1988, alleging robbery and homicide in the course of committing these crimes. Sia pleaded not guilty, and following a trial at the Regional Trial Court in Ilagan, Isabela, he was convicted of Murder on June 3, 1992. The court sentenced Sia to Reclusion Perpetua, ordered him to pay indemnity to the heirs of Aggabao, and dismissively addressed the presence of circumstantial evidence for conviction.
Victim and Circumstances of Death
Tranquilino Aggabao was a butcher who employed Sia in the procurement and butchering of pigs. On the morning of the crime, Aggabao was found dead near the public market, having sustained at least sixteen stab and hack wounds. The mode and timing of the attack suggest premeditation and intent to kill.
Testimonies and Evidence
The trial relied heavily on circumstantial evidence, with key testimonies from various witnesses, including:
- Luis Tan, an eyewitness who claimed to have seen Sia stab Aggabao. He retracted his initial silence due to fear and asserted his willingness to testify later.
- Elvira Aggabao, the victim's widow, who provided motive evidence against Sia, citing his gambling debts.
- Police Officials, including Jose Pinugu and Patrolman Potenciano Bagunu, who observed Sia with injuries shortly after the incident and discovered potentially blood-stained clothing linked to the accused.
Gaps and Missteps in the Trial Court's Judgment
The trial court dismissed Tan's direct testimony despite it being a critical eyewitness account, incorrectly stating that there were no direct witnesses. This omission raises concerns about the thoroughness of the trial court's evaluation of evidence and adherence to legal standards, particularly the requirement under Section 14, Article VIII of the 1987 Constitution, for due consideration of all evidence presented.
Accused's Defense and Alibi
Sia maintained a defense of alibi, claiming to have been at the market when the stabbing occurred and asserting that he borrowed a jacket from Rodolfo Yadan right before the murder. However, various testimonies contradicted his claims. Notably, police officer Taureano dela Rosa confirmed seeing Sia wearing the jacket earlier, the same jacket with blood stains later identified as human blood. The prosecution argued that the presumption of regularity in police duty bolstered their testimonies.
Court’s Findings: Circumstantial Evidence
The Supreme Court found that circumstantial evidence relied upon by the trial court failed to establish guilt beyond reasonable doubt. The criteria for circumstantial evidence were not fully met:
- Presence of multiple circumstances.
- Facts from which inferences are derived must be proven.
- The combination of circumstances must lead to a conviction beyond a reasonable doubt.
The evidence pointed towards a possible motive (Sia's debt to Aggabao) and presence at the crime scene, but without definitive p
...continue readingCase Syllabus (G.R. No. 157866)
Case Overview
- Accused-appellant Bernard Sia, also known as Narding, was charged with Robbery with Homicide in an information dated September 22, 1988.
- The crime, committed on December 2, 1987, in Cabagan, Isabela, involved violence against the victim, Tranquilino Aggabao, resulting in his death due to multiple stab and hack wounds.
Background of the Case
- Tranquilino Aggabao was a butcher who employed Sia to purchase and butcher pigs, with profits shared equally.
- Aggabao was killed near the public market, suffering massive hemorrhage from at least sixteen stab and hack wounds.
Trial Court Proceedings
- The Regional Trial Court found Sia guilty of Murder based on circumstantial evidence, sentencing him to Reclusion Perpetua, along with financial compensation to Aggabao's heirs.
- The court’s decision was issued on June 3, 1992.
Key Evidence Presented
- Luis Tan's Testimony: An eyewitness who saw Sia attack Aggabao but was not considered by the trial court, which erroneously stated no direct eyewitness testimony was available.
- Elvira Aggabao's Testimony: The victim's