G.R. No. L-57744 August 31, 1987
RAMON DORADO, petitioner, vs. COURT OF APPEALS and PEOPLE OF THE PHILIPPINES, respondents.

FACTS

Petitioner Ramon Dorado was prosecuted in 1958 for the murder of Manuel Villasis. After a protracted trial spanning fifteen years and involving multiple judges, he was convicted of homicide in 1973 by a judge who had not heard any live testimony. His conviction was affirmed by the Court of Appeals. Dorado’s subsequent petition for review to the Supreme Court faced procedural setbacks, initially dismissed for late filing and later hampered by his counsel’s alleged negligence, including the misplacement of a crucial retraction affidavit from the state witness, Leopoldo Barrios. Following a final plea, the Supreme Court set aside the entry of judgment and granted a hearing.
The prosecution’s case relied almost entirely on the testimonies of Barrios, who was discharged to become a state witness, and the victim’s widow, Millie Bisnar. Barrios testified that Dorado masterminded the killing due to a dispute over a carabao. However, his testimony was later recanted in a sworn affidavit, wherein he claimed his original statements were coerced by the PC and that he had no personal knowledge of the crime. The widow’s testimony was also found to be inconsistent and unreliable.

ISSUE

Whether the guilt of petitioner Ramon Dorado was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Dorado on the ground of reasonable doubt. The Court emphasized that a conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The core of the prosecution’s case was the testimony of Leopoldo Barrios, which was utterly discredited by his subsequent retraction. The Court ruled that a retraction does not automatically nullify original testimony, but when the original testimony is the sole basis for conviction and is later withdrawn, it creates a profound doubt as to the defendant’s guilt. Here, Barrios’s retraction was detailed, sworn, and presented a credible narrative of coercion, leaving no credible evidence to sustain the conviction.
Furthermore, the testimony of the widow was rife with inconsistencies and improbabilities, failing to corroborate the discredited account. The Court also noted the extraordinary delay in the proceedings and the fact that the convicting judge decided the case based solely on the cold record. Considering the totality of the circumstances—the recanted and uncorroborated testimony, the unreliable witness account, and the long history of procedural mishaps—the evidence failed to meet the required moral certainty for a criminal conviction. The decision underscores that the constitutional presumption of innocence must prevail when the evidence adduced is insufficient to prove guilt beyond reasonable doubt.