G.R. No. 111742 March 26, 1998
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROMAN MENESES Y MARIN, accused-appellant

FACTS

On December 15, 1991, around 3:00 AM, Cesar Victoria was stabbed to death while sleeping in a rented makeshift room in Tondo, Manila, with his seven-year-old son, Christopher Victoria. Appellant Roman Meneses, the victim’s brother-in-law, was charged with murder. The prosecution’s case relied primarily on the eyewitness account of Christopher, who testified he saw his father being stabbed with a “veinte nueve” (fan knife/balisong). SPO3 Jaime Mendoza, the investigating officer, testified that when initially questioned at the crime scene, Christopher could not name or describe the attacker but said he could identify him by face. Later, during a confrontation at the police station on December 26, 1991, Christopher identified appellant as the assailant. SPO3 Eduardo Gonzales testified he arrested appellant on December 25, 1991, based on a report from appellant’s wife, Angelina Victoria, and that appellant was found with a balisong and later verbally admitted to the stabbing at the station. Medico-Legal Officer Florante Baltazar testified the victim sustained five stab wounds, two fatal, and opined the victim could have been standing or sitting when stabbed. The appellant interposed the defense of denial and alibi, testifying he was in Pampanga at the time of the crime, was arrested without a warrant, mauled by police, and never admitted to the killing. The Regional Trial Court convicted appellant of murder and sentenced him to reclusion perpetua.

ISSUE

Whether the prosecution proved the guilt of the appellant beyond reasonable doubt based on the credibility of the lone child eyewitness identification.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED the appellant on the ground of reasonable doubt. The Court found the trustworthiness of Christopher Victoria’s identification to be dubious. The crime occurred around 3:00 AM in a dark, makeshift room (3×5 meters) with no established source of illumination, making it highly improbable for a child, just roused from sleep, to reliably identify the attacker or the specific knife used. Furthermore, there was a glaring discrepancy in SPO3 Mendoza’s testimony: on direct and cross-examination, he stated Christopher could not name or describe the attacker at the scene, but on re-direct, he claimed Christopher categorically named appellant, Roman Meneses. The Court also noted the inherent suggestibility of a police station confrontation for identification. The medico-legal opinion that the victim may not have been lying down when stabbed did not necessarily discredit Christopher’s account, as it pertained to the victim’s position, not the identity of the assailant. The defense of alibi was weak, but conviction must rest on the strength of the prosecution’s evidence, which failed to prove guilt beyond reasonable doubt. The constitutional presumption of innocence prevails.