3/28/25, 10:43 AM People vs.
Hassan y Ayun
Title
People vs. Hassan y Ayun
Case Decision Date
G.R. No. 68969 Jan 22, 1988
A 15-year-old illiterate pushcart worker, Usman Hassan, was acquitted of murder due to
flawed identification, weak evidence, and inadequate police investigation, highlighting
procedural failures and reasonable doubt.
Jur.ph - Case Digest (G.R. No. 68969)
Legal Reasoning Model
Facts:
Case Background and Procedural History
The case involves a pauper’s appeal from the decision of the Regional Trial Court
(RTC) of Zamboanga City, Branch XIII, rendered on January 25, 1984.
The petitioner is the People of the Philippines while the respondent is Usman
Hassan y Ayun.
The trial court had found the accused guilty beyond reasonable doubt as the
principal in the crime of murder and imposed reclusion perpetua, along with
accessory penalties and an indemnity to the heirs of the deceased.
The decision was ultimately reversed on appeal, resulting in the acquittal of the
accused.
Circumstances of the Crime and Background of Parties
The victim, Ramon Pichel, Jr. y Uro, aged 24, was a single manager in his father’s
sand and gravel business and was killed on July 23, 1981 through a stabbing.
The accused, Usman Hassan, was described as a 15-year-old pushcart cargador,
characterized by his poverty, marginalization, and lack of formal education.
Usman’s background was marked by displacement and poverty, having been forced
to move several times due to local conflicts and internal strife.
His birth was not formally registered because of the local customs of the Samal
tribe, to which he belongs.
Investigation and Identification Procedures
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3/28/25, 10:43 AM People vs. Hassan y Ayun
The primary evidence against the accused consisted of the testimony of a single
eyewitness, Jose Samson, a 24-year-old who was employed by the victim’s family at
the sand and gravel business.
Samson testified that he saw Ramon Pichel, Jr. with the accused and later witnessed
an unidentified assailant stabbing the victim as he was seated on his motorcycle.
His account described the assailant as wearing a white, short-sleeved t-shirt and
maong pants, and noted that the stabbing occurred “only once.”
The police investigation, led by Police Corporal Rogelio Carpio of the Homicide and
Arson Section, involved an identification procedure wherein the accused was
confronted with Samson at the La Merced Funeral Homes.
Although initially indicated as a confrontation, Carpio later mentioned that it was
conducted as a “police line-up,” creating discrepancies in the method of
identification.
The procedure was criticized for being suggestive and conducted in an
environment that could compromise the reliability of the eyewitness identification.
Additional evidence included statements and exhibits such as:
A sworn statement by eyewitness Samson taken within a couple of days after the
crime.
A “Case Report” by Corporal Carpio which essentially mirrored Samson’s sworn
statement.
The confiscation of a knife from the accused during arrest, which measured
approximately seven inches but was not adequately subjected to forensic testing.
The investigation was noted to be superficial, with certain potential witnesses (e.g.,
a fruit vendor present at the scene) not being investigated or questioned.
Inconsistencies and Flaws in the Evidence
The testimony of the sole eyewitness was found to be inconsistent and weak when
subjected to cross-examination.
The analyst testimony of the medico-legal officer contradicted key elements of the
eyewitness account by indicating two stab wounds instead of one and asserting that
the fatal wound was inflicted while the victim was facing the assailant.
The police investigator’s handling of identification – by presenting the accused
singly to Samson in a confrontation rather than a formal lineup – was deemed
improper and suggestive, likely influencing the witness’s testimony.
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3/28/25, 10:43 AM People vs. Hassan y Ayun
Procedural lapses included the hastily taken and sworn eyewitness statement and
the failure to explore other leads such as examining the knife for forensic evidence
like blood traces.
Additional Circumstantial Context
The absence of a clearly established motive on the part of the accused was noted,
particularly as the victim was a complete stranger.
Usman Hassan’s alibi, which stated that he was at a nearby public area waiting for
transportation, was given scant consideration and left largely unexamined by the
trial court.
Challenges were also raised regarding the accused’s age. Testimony by his mother
and a later dental assessment provided a broad age range (14 to 21 years), though
the court ultimately observed that he was about 18 years old at the time of the
incident.
The overall background of the accused emphasized his status as a marginalized
individual, highlighting concerns about the fairness of the investigative process and
the application of justice given his socio-economic disadvantage.
Issue:
Sufficiency of Evidence
Whether the testimony of the lone eyewitness and the police evidence were
sufficient to establish the guilt of the accused beyond reasonable doubt.
Whether the inconsistencies in witness statements and forensic testimony
undermined the prosecution’s case.
Identification Procedure
Whether the police-conducted identification (confrontation versus lineup) of the
accused was proper and free from suggestiveness.
Whether the identification process violated the accused’s constitutional right to due
process and counsel.
Investigative Lapses
Whether the police investigation was thorough and properly conducted,
particularly regarding the handling of forensic evidence (e.g., the untested knife)
and interviewing of potential material witnesses.
Whether the shortcomings in the investigation contributed to the prejudicial
presentation of evidence against the accused.
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3/28/25, 10:43 AM People vs. Hassan y Ayun
Age and Mitigating Circumstances
Whether the failure to conclusively establish the accused’s age (potentially a minor)
should have been given more weight as a mitigating circumstance in assessing
criminal liability.
Whether the trial court’s procedural approach and clarifying questions exhibited
fairness and sensitivity to the accused’s vulnerable status.
Ruling:
(Subscriber-Only)
Ratio:
(Subscriber-Only)
Doctrine:
(Subscriber-Only)
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