Robert Pagayon was found dead in a well on Benjie Pabiona's property. Pabiona and four others claimed Pagayon fell, while a witness said he saw the five men attacking an unidentified person by the river who was later identified as Pagayon. The court initially convicted the five men of murder. However, the court overturned the conviction, finding the evidence was circumstantial and could indicate either an accident or a crime. As there were two plausible explanations, and the prosecution did not prove motive or all elements of the crime, there was reasonable doubt about the men's guilt. The court ruled Pabiona and the others were not liable for murder.
Robert Pagayon was found dead in a well on Benjie Pabiona's property. Pabiona and four others claimed Pagayon fell, while a witness said he saw the five men attacking an unidentified person by the river who was later identified as Pagayon. The court initially convicted the five men of murder. However, the court overturned the conviction, finding the evidence was circumstantial and could indicate either an accident or a crime. As there were two plausible explanations, and the prosecution did not prove motive or all elements of the crime, there was reasonable doubt about the men's guilt. The court ruled Pabiona and the others were not liable for murder.
Robert Pagayon was found dead in a well on Benjie Pabiona's property. Pabiona and four others claimed Pagayon fell, while a witness said he saw the five men attacking an unidentified person by the river who was later identified as Pagayon. The court initially convicted the five men of murder. However, the court overturned the conviction, finding the evidence was circumstantial and could indicate either an accident or a crime. As there were two plausible explanations, and the prosecution did not prove motive or all elements of the crime, there was reasonable doubt about the men's guilt. The court ruled Pabiona and the others were not liable for murder.
Robert Pagayon was found dead in a well on Benjie Pabiona's property. Pabiona and four others claimed Pagayon fell, while a witness said he saw the five men attacking an unidentified person by the river who was later identified as Pagayon. The court initially convicted the five men of murder. However, the court overturned the conviction, finding the evidence was circumstantial and could indicate either an accident or a crime. As there were two plausible explanations, and the prosecution did not prove motive or all elements of the crime, there was reasonable doubt about the men's guilt. The court ruled Pabiona and the others were not liable for murder.
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PEOPLE VS PABIONA
(GR. No. 145803, June 30, 2004)
FACTS: Robert Pagayon was working under the accused when found dead. According to the accused they saw Pagayon who was said fell down the well, which the victim and the five accused working on inside Pabionas property, they found them dead. Pabiona stated that they tried to resuscitate the victim and summon his mother to let her know. Emma Pagayon, the victims sister-inlaw, insisted to have an autopsy reports and later found out that the victim cause of death is Cardio respiratory arrest due to shock and hemorrhage as a result of multiple traumatic injuries to the body. Michael Pagayon, cousin of the victim, further testified that he saw the five accused mauling unidentified person near the river, and he later said that the unidentified person was Robert Pagayon. The court rendered a decision convicting the five accused,Benjie Pabiona, Roselo Basalatan, Antonio Silarca, and Roberto Metano guilty of crime of murder beyond reasonable doubt. However, the accused file a notice of appeal for relying only to circumstantial evidences and disregarded appellants version of the case. ISSUE: Whether or not there is sufficient circumstantial evidence and Pabiano and other are liable of the crime of murder? RULING: No. The Court applies the principle of equipoise rule stated that facts and circumstances are capable of two or more explanations, one consistent with the innocence of the accused and the other consistent with his guilt, then the evidence does not fulfill the test of moral certainty and will not justify a conviction. In the case at bar, the evidences showed that it can also be an accident, falling down and getting hit in the head with a hard object, may cause blood clot and scalp hematoma. Under Section 4 of Rule 133 of the Rules on Evidence provides that circumstantial evidence is sufficient for conviction if the following requisites are complied with: (1) there is more than one circumstance; (2) the facts from which the inferences are derived are proven; and (3) the combination of all the circumstances is such as to produce a conviction beyond reasonable doubt. However because of the consistent version statements of the appellants and other circumstantial evidence causing doubt to whether a crime has been committed or whether the accused has committed it. Also the prosecution was unable to establish motive of the appellants in committing such unlawful act, relying only in suspicion that probably the accused perform the crime. Failed to suffice the
evidence and prove the guilt. Therefore, Pabiano and other are not liable for the crime of murder.