G.R. No. L-60388 November 21, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BERTITO BACUS alias BALODOY, ABUNCIO SUMALPONG alias BUNCIONG, ARNOLD ARGUELLES alias MANOLO SOTTO MANOS, and ANTONIO POLERAN alias JUNIOR POLERAN, accused, ARNOLD ARGUELLES alias MANOLO SOTTO MANOS, appellant.

FACTS

Vicente Sumalpong was killed in his home on March 17, 1970. His wife and granddaughter testified that two men entered their house, announced a hold-up, and shot the victim. The initial police investigation yielded no suspects. Over two months later, Police Lieutenant Ciriaco Gonzales took over the case. His investigation centered on a land dispute between the victim and his brother, leading him to suspect the brother’s son, Abuncio Sumalpong. A witness, Carmelita Orpiala, later informed Gonzales that she overheard Abuncio Sumalpong, Bertito Bacus, and Arnold Arguelles planning the killing. Based largely on this hearsay information and subsequent extrajudicial confessions obtained from Bacus and Sumalpong, which implicated Arguelles as the triggerman, all four accused were charged with murder. The trial court convicted them, imposing the death penalty on Bacus, Sumalpong, and Arguelles. Bacus and Sumalpong later withdrew their appeals. This automatic review proceeded only for appellant Arnold Arguelles.

ISSUE

Whether the guilt of appellant Arnold Arguelles was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Arnold Arguelles. The Court found the evidence against him insufficient to meet the standard of proof beyond reasonable doubt. The case rested primarily on the extrajudicial confessions of his co-accused, Bertito Bacus and Abuncio Sumalpong, which implicated Arguelles. However, these confessions are inadmissible against Arguelles, as they are hearsay under the res inter alios acta rule. The Court emphasized that an extrajudicial confession is binding only on the confessant and not on his co-accused. The lone eyewitness, Carmelita Orpiala, did not positively identify Arguelles at trial, creating reasonable doubt. Furthermore, the Court noted the confessions were obtained under questionable circumstances, with the police failing to observe constitutional safeguards. With the confessions excluded as to Arguelles, the remaining evidence—the weak and inconsistent eyewitness testimony—was utterly inadequate to sustain a conviction. The prosecution failed to present any direct, credible evidence linking Arguelles to the crime. Where the evidence does not overcome the presumption of innocence, acquittal is mandatory.