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PEOPLE v. MUHAMMAD ABDULAH

FACTS:

On November 6, 1992, appellant Mohamad "Bong" Abdulah, along with his companion, forcibly entered the house of Romelyn Diolago. Present in the house were Romelyn's mother, Evelyn Aguirre, and her sister, Jovy Aguirre. Appellant proceeded to drag Evelyn out of the house and forced her into a car, while his companion held a gun to Jovy and coerced her into joining them as well. It was discovered that three other men were already inside the car. Appellant then menacingly threatened the neighbors before driving away. The next day, the bodies of three women were found in Taguig City. These bodies were later identified as Evelyn, Romelyn, and Jovy. Appellant was charged with three counts of murder. Initially, he entered a not guilty plea and claimed mistaken identity. However, the trial court found him guilty, and this decision was subsequently affirmed by the Court of Appeals. The Supreme Court is now reviewing the case.

ISSUES:

  1. Whether the circumstances proven during the trial constitute an unbroken chain leading to the fair and reasonable conclusion that the appellant is guilty of the crime charged.

  2. Whether the positive identification of the appellant by the prosecution witnesses is sufficient to establish his guilt beyond reasonable doubt.

  3. Whether the circumstantial evidence and positive identification of the appellant are sufficient to convict him for the killing of the victims.

  4. Whether the appellant's defenses of denial and alibi are credible.

  5. Whether the appellant should be held liable for the death of all the victims.

RULING:

  1. Yes, the circumstances proven during the trial amount to an unbroken chain leading to the fair and reasonable conclusion that the appellant is guilty of the crime charged.

  2. Yes, the positive identification of the appellant by the prosecution witnesses is sufficient to establish his guilt beyond reasonable doubt.

  3. Yes. The circumstantial evidence and positive identification of the appellant are sufficient to convict him for the killing of the victims.

  4. No. The appellant's defenses of denial and alibi are not credible.

  5. No. The appellant should only be held liable for the death of the victims Evelyn and Jovy, as there is no evidence to show that he also abducted Romelyn.

PRINCIPLES:

  • A judgment of conviction based on circumstantial evidence can be upheld if the circumstances proven constitute an unbroken chain leading to the fair and reasonable conclusion that the defendant is guilty, to the exclusion of any other conclusion.

  • A conviction based on circumstantial evidence must exclude each and every hypothesis consistent with the accused's innocence.

  • Positive identification of the accused by prosecution witnesses can be sufficient to establish guilt beyond reasonable doubt.

  • Circumstantial evidence and positive identification can be sufficient to establish guilt beyond reasonable doubt.

  • Denial and alibi as defenses must be substantiated by clear and convincing proof.

  • Qualifying and aggravating circumstances must be proven with equal certainty as the commission of the criminal offense.

  • Every qualifying or aggravating circumstance alleged to have attended a killing must be proven by the same degree of proof.

  • The indeterminate penalty for each count of homicide should be within the range of prisión mayor as minimum to reclusión temporal in its medium period as maximum.

  • In cases of homicide, civil indemnity of P50,000.00 and moral damages of P50,000.00 should be awarded to the heirs of each victim.