G.R. No. 120898 -99 May 14, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFONSO BAUTISTA, accused-appellant.

FACTS

Accused-appellant Alfonso Bautista was convicted by the Regional Trial Court of Urdaneta, Pangasinan, in two consolidated cases: Criminal Case No. U-8191 for illegal possession of firearm and ammunition, and Criminal Case No. U-8192 for the complex crime of murder with frustrated murder and attempted murder. The charges stemmed from a shooting incident on May 18, 1992, during a barangay fiesta in Pozorrubio, Pangasinan, which resulted in the death of Barangay Captain Eduardo Datario and injuries to Bernabe Bayona and Cinderella Estrella. The prosecution’s case primarily relied on the testimonies of two alleged eyewitnesses, Ferdinand Datario (the victim’s brother) and Rolando Nagsagaray, who claimed to have seen appellant holding a long firearm and shooting the victims from behind a concrete fence. Both witnesses admitted they did not report appellant’s alleged involvement to anyone for over sixteen months, breaking their silence only after appellant was arrested in September 1993. Appellant denied the charges, presenting an alibi that he was attending a birthday celebration at a neighbor’s house at the time of the incident, and claimed he was tortured into confessing after his arrest.

ISSUE

Whether the trial court erred in convicting accused-appellant based on the testimonies of the prosecution eyewitnesses, given their sixteen-month delay in reporting the incident and the alleged inconsistencies and improbabilities in their accounts.

RULING

Yes. The Supreme Court REVERSED and SET ASIDE the trial court’s decision and ACQUITTED accused-appellant Alfonso Bautista. The Court found the prolonged silence of the eyewitnesses for over sixteen months, without satisfactory explanation, rendered their testimonies unreliable and insufficient to prove guilt beyond reasonable doubt. The witnesses’ claim of fear was deemed unreasonable as they had multiple safe opportunities to report anonymously or to trusted authorities. The Court also noted inconsistencies in their testimonies regarding the lighting conditions and their positions relative to the shooter. Furthermore, the prosecution failed to establish the essential element of illegal possession of a firearm, as the alleged weapon was never recovered or presented. The defense of alibi, while generally weak, assumed significance due to the prosecution’s failure to discharge its burden of proof. The constitutional presumption of innocence prevailed, and the evidence did not meet the required moral certainty for conviction.