G.R. No. 20238; July 28, 1923
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. BERNARDO BAYQUEN, defendant-appellant.

FACTS

On July 6, 1921, four individuals (Manuel Valera, Mateo Valera, Nicolas Valera, and Marcos Bersamira) broke into a home in Bangued, Abra, and murdered two women, ostensibly to rob them. The perpetrators were recognized, fled without taking anything, and later made detailed confessions stating that no one else was involved. They were convicted and sentenced to life imprisonment. More than sixteen months later, an information was filed against Bernardo Bayquen, a first cousin of one victim, charging him as a conspirator. The prosecution’s case relied almost entirely on the testimonies of three of the convicted murderers (Manuel, Mateo, and Marcos), who claimed Bayquen advised them to kill the women if recognized. Nicolas Valera testified for the defense, exonerating Bayquen. Evidence indicated the accusation arose after Manuel Valera received a letter from his brother Esteban, a political enemy of Bayquen, suggesting Bayquen be implicated.

ISSUE

Whether the testimonies of the three self-confessed murderers, without corroboration, are sufficient to prove the guilt of Bernardo Bayquen beyond a reasonable doubt.

RULING

No. The Supreme Court reversed the judgment of conviction and acquitted Bernardo Bayquen. The Court held that the uncorroborated testimonies of the self-confessed murderers were vague, indefinite, and uncertain. They provided no details on the alleged conspiracy—such as what was specifically said, by whom, where, and when, aside from one alleged meeting. Their testimonies also conflicted with their original confessions, which expressly stated no other person was involved. Given the presumption of innocence, the instigation of the prosecution by a political enemy long after the crime, and the absence of any corroborating evidence, the proof was insufficient to establish guilt beyond a reasonable doubt.