GR 87184 85; (October, 1991) (Digest)
G.R. No. 87184 -85, October 3, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICHARD VIRAY and ALFREDO DOMINGO, accused-appellants.
FACTS
The accused-appellants, Richard Viray and Alfredo Domingo, were convicted by the Regional Trial Court of Manila for the crime of Robbery with Homicide. The prosecution’s case, primarily based on the testimony of eyewitness Merle Salinas, alleged that on October 5, 1987, the appellants, along with two others, mauled Orlando Eugenio. During the assault, they took his personal belongings. Viray then lifted and boxed Eugenio, causing him to fall into an estero where he drowned. His body was recovered days later. The trial court found the testimony of Salinas credible and convicted both appellants, sentencing them to reclusion perpetua.
The defense interposed alibi. Viray claimed he was at a friend’s house, while Domingo asserted he was at home sleeping at the time of the incident. On appeal, they argued that the prosecution failed to prove their guilt beyond reasonable doubt, highlighting inconsistencies in Salinas’s testimony and the lack of direct evidence linking the robbery to the killing.
ISSUE
Whether the guilt of the accused-appellants for the crime of Robbery with Homicide was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the accused-appellants. The Court meticulously scrutinized the prosecution evidence and found it insufficient to establish moral certainty of guilt. The testimony of the lone eyewitness, Merle Salinas, was fraught with material inconsistencies regarding critical details such as the lighting conditions, her ability to identify the assailants, and her conduct immediately after the incident. The Court emphasized that for a conviction to stand, the evidence must be credible and consistent. Here, the inconsistencies created reasonable doubt as to the veracity of her account.
The legal logic is anchored on the constitutional presumption of innocence and the prosecution’s burden to prove guilt beyond reasonable doubt. The Court reiterated that a conviction must rest on the strength of the prosecution’s case, not on the weakness of the defense. While the defense of alibi is inherently weak, it gains significance when the prosecution’s evidence is unreliable. The prosecution’s failure to present a solid, consistent, and credible narrative meant it did not overcome the presumption of innocence. Consequently, the required quantum of proof was not met, necessitating an acquittal.