G.R. Nos. 101564-65 September 30, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DAVID POSADAS, SR., DAVID POSADAS, JR., RODOLFO MORALES alias “Rudy”, FRANKLIN BUENAVISTA, MARCIAL POSADAS, DANILO POSADAS, ALFREDO MAGNO & ANASTACIO BARTULINA alias “Anastacio Batilano”, accused, FRANKLIN BUENAVISTA, appellant.

FACTS

Accused David Posadas, Sr., Danilo Posadas, Marcial Posadas, and Franklin Buenavista were convicted of murder by the Regional Trial Court. Their co-accused Rodolfo Morales died, while David Posadas, Jr., Alfredo Magno, and Anastacio Bartulina remained at-large. David Posadas, Sr., Marcial Posadas, and Danilo Posadas withdrew their appeal, leaving only Franklin Buenavista’s conviction for review. The prosecution’s case, based on state witness Conrado Gatilago’s testimony, established that on August 13, 1984, David Posadas, Sr. convinced Rodolfo Morales to kill Arthur Maravilla. A group including the Posadases, Morales, Magno, Bartulina, and Gatilago agreed to the plan, distributed firearms, and verified Maravilla’s presence at his house on Tambalisa Island. The group went to appellant Franklin Buenavista’s house, which was near Maravilla’s, and inquired if Maravilla was home; Buenavista answered affirmatively. The group then left, leaving Buenavista behind. They later mauled and tied Maravilla’s caretaker, Eliseo Santos, to a tree. The group returned to Buenavista’s house, and David Posadas, Sr. ordered Buenavista to call Sixto Santos (Eliseo’s son and Maravilla’s helper) to inform him his father was tied up, intending to lure Sixto out so Maravilla would be alone. Buenavista obeyed. When Sixto and another man came out, David Posadas, Jr. and Morales fired at them, forcing them to flee. Maravilla then emerged, was shot by David Posadas, Jr., and subsequently shot by Morales and Bartulina and hacked by David Posadas, Jr., resulting in his death from multiple gunshot and hack wounds.

ISSUE

Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant Franklin Buenavista for the crime of murder.

RULING

The Supreme Court REVERSED the trial court’s conviction and ACQUITTED Franklin Buenavista based on reasonable doubt. The Court held that the evidence did not clearly establish Buenavista’s participation in the killing. His actions—merely confirming Maravilla was home when asked by the group and later obeying an order to call Sixto Santos—did not prove he was an active or willing participant in the conspiracy to kill Maravilla. The Court noted the group consisted of eight fully-armed men, and Buenavista’s compliance could have been out of a natural sense of self-preservation or coercion. In line with the constitutional presumption of innocence, any doubt as to guilt must be resolved in favor of the accused. The Solicitor General’s manifestation praying for acquittal, on grounds of lack of evidence of participation and that Buenavista was coerced, was agreed with by the Court.