G.R. No. 979 , February 12, 1903
THE UNITED STATES, complainant-appellee, vs. EUSEBIO SANTA CRUZ, defendant-appellant.

FACTS:
The defendant, Eusebio Santa Cruz, was convicted in the lower court of the crime of robbery with violence to the person. The prosecution’s case primarily relied on the testimony of the alleged victim, Ri-Jhorumal, a young Hindoo boy employed in a shop on the Escolta in Manila. Ri-Jhorumal testified that his employer gave him ten pesos in silver to buy thread at the Tondo market. While in a street near the market at about 11 o’clock in the morning, he was allegedly robbed by two men. One man held his hand over the boy’s mouth while the other took the money from his pocket. Ri-Jhorumal identified the defendant as the man who covered his mouth. His employer corroborated only the fact that he gave the boy money for an errand. The prosecution presented another witness, Claudio Subit, whom the boy claimed saw the incident, but Subit denied witnessing any robbery. The defense presented evidence from several witnesses to establish an alibi for the accused.

ISSUE:
Whether the evidence presented by the prosecution is sufficient to establish the guilt of the accused beyond a reasonable doubt.

RULING:
No. The Supreme Court reversed the judgment of conviction. The Court found the prosecution’s evidence insufficient to exclude a reasonable doubt as to the accused’s guilt. The Court noted the inherent improbability of such a violent robbery occurring in broad daylight in a central part of a large city without attracting the attention of others, aside from the uncorroborated testimony of the complaining witness. The sole eyewitness testimony of the victim was contradicted by the witness he claimed saw the event. In the absence of corroborating circumstances, the evidence failed to meet the required standard of proof. The case was remanded to the lower court for further proceedings consistent with the opinion.