G.R. No. 128286 July 20, 1999
PEOPLE OF THE PHILIPPINES, plaintiff, vs. GILBERT BASAO y MACA and PEPE ILIGAN y SALAHAY, accused, PEPE ILIGAN y SALAHAY, accused-appellant.

FACTS

Accused-appellant Pepe Iligan was charged with robbery and two counts of murder for the killing of Police Inspector Joerlick Faburada and his wife, Dra. Arlyn Faburada, on April 14, 1994. The prosecution alleged that Iligan, conspiring with his co-accused Gilbert Basao, shot the victims along a national highway and thereafter robbed the slain police officer of his firearm, radio, and ring. Initially, only Basao was tried, as Iligan remained at large. The trial court acquitted Basao in October 1996, finding the prosecution’s evidence insufficient to prove his identity and guilt beyond reasonable doubt. Iligan was subsequently arrested and arraigned. At his separate trial, the prosecution’s case hinged primarily on the testimony of his previously acquitted co-accused, Gilbert Basao, and another witness, Reynaldo Angeles.

ISSUE

The core issue is whether the guilt of accused-appellant Pepe Iligan for the crimes of robbery and two counts of murder was proven beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED accused-appellant Pepe Iligan. The Court found the prosecution’s evidence utterly insufficient to establish his guilt beyond a reasonable doubt. The testimony of Gilbert Basao, the principal witness, was deemed inherently unreliable. As a previously acquitted co-accused, Basao had a natural and powerful motive to falsely implicate Iligan to exculpate himself. His testimony was uncorroborated by any other credible evidence and was riddled with inconsistencies. The Court emphasized that the testimony of an accomplice, while admissible, is inherently suspect and must be received with utmost caution. For such testimony to sustain a conviction, it requires substantial corroboration on material points, which was completely absent in this case. The other witness, Reynaldo Angeles, failed to positively identify Iligan as a participant in the crime. The prosecution’s case thus collapsed, as it failed to meet the quantum of proof required for a criminal conviction. The constitutional presumption of innocence prevailed. The Court further ruled that the trial court erred in convicting Iligan based solely on the discredited testimony of an interested witness, violating the fundamental principle that guilt must be established by proof beyond reasonable doubt, not by mere suspicion or conjecture.