GR L 689; (June, 1948) (Digest)
G.R. No. L-689; June 9, 1948
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAFAEL DAYAGANON, defendant-appellant.
FACTS
On the night of August 13, 1944, in Canmano, Clarin, Bohol, Aniceto Albiso was called from his house by an unknown man requesting a guide to the barrio road of Cambitoon. Albiso acceded and led the way. His daughter observed appellant Rafael Dayaganon and Pedro Albares following behind. Albiso’s wife, Fausta, followed to warn her husband, as Dayaganon was known to be his enemy due to a prior quarrel where Albiso had inflicted serious injuries on Dayaganon, including cutting part of his ear. Before she could reach them, a gunshot was heard. Albiso was found dead from a bullet wound in the back. Evidence showed that earlier that evening, Dayaganon was seen loading his revolver at a road junction. After the shot, a prosecution witness heard Dayaganon shout that he had his revenge on “Cito” (Aniceto) and had hit him in the back. The defense presented an alibi, claiming Dayaganon was at a prayer meeting at the time.
ISSUE
Whether the trial court erred in convicting appellant Rafael Dayaganon of murder based on the credibility of the prosecution witnesses.
RULING
No. The Supreme Court affirmed the conviction. The trial court’s assessment of witness credibility is accorded great respect, as it observed their demeanor firsthand. The prosecution evidence established beyond reasonable doubt that Dayaganon was at the scene, had motive due to the prior quarrel, was seen loading his firearm, and was heard claiming responsibility for the killing after the gunshot. The killing was qualified by treachery, as the victim was shot from behind while unarmed and unaware. No aggravating or mitigating circumstances were sufficiently proven, so the penalty was imposed in the medium period. The Court affirmed the judgment sentencing Dayaganon to reclusion perpetua, with indemnity to the heirs and costs.
Separate Opinion: Justice Perfecto, dissenting, argued that the evidence did not establish guilt beyond reasonable doubt. He highlighted the lack of an eyewitness to the shooting, the unreliable identification by voice of the appellant’s alleged exclamation, and the failure of key prosecution witnesses to report the incident or testify before the guerrilla authorities at the time. He voted for acquittal, with Justice Briones concurring.
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