GR 27608; (July, 1973) (Digest)
G.R. No. L-27608 July 6, 1973
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FILOTEO MANIPULA, FERNANDO AZUCENA, QUIRINO AZUCENA, JOAQUIN LAUTRISO, and LEOPOLDO AZUCENA, accused. FERNANDO AZUCENA and QUIRINO AZUCENA, appellants.
FACTS
This is an automatic review of death sentences imposed on appellants Fernando and Quirino Azucena for robbery with homicide. The prosecution alleged that on March 10, 1965, the five accused, who were relatives of the victims, killed spouses Modesto Ayusip and Visitacion Manipula in Iloilo and robbed them. The prosecution’s case heavily relied on the extra-judicial confession of co-accused Leopoldo Azucena, whom they sought to discharge as a state witness. The trial court denied this motion, finding Leopoldo’s statement uncorroborated and in direct conflict with the testimony of another witness, Conrado Azucena. Despite this prior finding, the trial court later convicted the appellants, primarily based on this very same discredited confession from Leopoldo, whom it acquitted.
ISSUE
Whether the guilt of the appellants was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the appellants due to the utter insufficiency of the prosecution’s evidence, a conclusion concurred with by the Solicitor-General. The Court’s legal logic centered on the fundamental principle that a conviction must rest on proof beyond reasonable doubt. The trial court committed a grave and fatal inconsistency by acquitting Leopoldo Azucena after expressly rejecting his confession as unreliable and uncorroborated, yet subsequently using that same repudiated confession as the sole basis to convict the other accused. The Court emphasized that an extra-judicial confession is admissible only against the confessant and cannot be used to implicate co-accused. With Leopoldo’s confession effectively discarded, the prosecution’s case collapsed, as there was no other competent evidence placing the appellants at the crime scene. The absence of recovered weapons or stolen property further weakened the case. Consequently, the appellants’ defenses of alibi and denial gained proportionate strength. The burden of proof always remains with the prosecution, and its failure to present credible, positive identification of the perpetrators warranted acquittal. The death sentences were set aside, and the appellants were ordered immediately released.