G.R. No. 182518 January 20, 2009
PEOPLE OF THE PHILIPPINES, Appellee, vs. MUHAMMAD ABDULAH, alias “BONG ABDULAH,” alias “BONG HASAN ZAMAN,” Appellant.

FACTS

On November 6, 1992, appellant Muhammad Abdulah, along with companions, went to the house of Romelyn Diolago in Intramuros, Manila, looking for her. Romelyn’s mother, Evelyn Aguirre, and sister, Jovy Aguirre, were present. Informed that Romelyn was at a night club, appellant decided to fetch her. He forcibly dragged Evelyn from the house to a black car. A companion, Latip Mangsungayan, poked a gun at Jovy, dragged her, and pushed her into the car. Appellant threatened onlookers to not interfere or speak about the incident, then drove away with Evelyn and Jovy. The following day, November 7, 1992, the dead bodies of Evelyn, Jovy, and Romelyn were found in Maharlika Village, Taguig, with stab wounds and ligature marks on their necks. Appellant was charged with three counts of murder. The prosecution’s case was built on circumstantial evidence and the positive identification of appellant by witnesses Leny Aguirre (Evelyn’s daughter) and neighbor Sabina Badilla. Appellant denied the charges, claiming mistaken identity and presenting an alibi that he was in Cotabato City at the time. The Regional Trial Court convicted appellant of three counts of murder, sentencing him to reclusion perpetua for each count and ordering him to pay indemnity and moral damages. The Court of Appeals affirmed the decision in toto.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to convict appellant of three counts of murder beyond reasonable doubt.

RULING

Yes, the circumstantial evidence is sufficient for conviction. The Supreme Court affirmed the conviction but modified the penalty. The proven circumstances form an unbroken chain leading to the conclusion that appellant is guilty beyond reasonable doubt. These circumstances are: (1) appellant and companions went to Romelyn’s house; (2) appellant asked for Romelyn’s whereabouts; (3) appellant forcibly dragged Evelyn and Jovy from the house to a car; (4) a companion poked a gun at Jovy; (5) appellant threatened onlookers; (6) appellant drove away with the victims; (7) the victims’ bodies were found the next day in Taguig; and (8) the bodies had stab wounds and ligature marks. Appellant was positively identified by prosecution witnesses. The combination of these circumstances excludes any reasonable hypothesis of innocence. However, the qualifying circumstances of treachery and evident premeditation were not proven with certainty. Therefore, the crimes are deemed homicide, not murder. Appellant is found guilty of three counts of homicide and sentenced to an indeterminate penalty of eight years and one day of prision mayor as minimum to fourteen years, eight months, and one day of reclusion temporal as maximum for each count. Appellant is ordered to pay the heirs of each victim P50,000.00 as civil indemnity and P50,000.00 as moral damages.