G.R. Nos. 98425-26 May 21, 1993
People of the Philippines, plaintiff-appellee, vs. Reynaldo Aguilar alias “Nonong”, accused-appellant.

FACTS

On the evening of August 1, 1989, at Sitio Simsiman, Barangay Marguez, Esperanza, Sultan Kudarat, Marcelino Aquino was shot and killed while shelling corn under his house with his mother, Lilia Aquino. Following the initial gunshot, three more gunshots were heard from different directions, and a hand grenade was lobbed into the house, injuring Lilia Aquino, Ailleen Aquino, and Argie Aquino. Based on claims by Ailleen Aquino and her husband Salustiano Aquino that one of the perpetrators was Nonong Aguilar, criminal complaints for Murder and Multiple Frustrated Murder were filed against Reynaldo Aguilar alias “Nonong” and two unidentified persons. Informations were subsequently filed with the Regional Trial Court (RTC). During arraignment, Aguilar pleaded not guilty. The prosecution presented witnesses Salustiano Aquino, Lilia Aquino, and Ailleen Aquino, who testified that Ailleen saw Aguilar standing near their kitchen holding a long firearm immediately after the grenade explosion and that Salustiano also recognized him. The defense presented alibi, with Aguilar claiming he was asleep in his house at the time and was later awakened by gun reports and an explosion. The RTC convicted Aguilar of Murder and Multiple Attempted Murder, sentencing him to Reclusion Perpetua for Murder and an indeterminate penalty for Multiple Attempted Murder. Aguilar appealed.

ISSUE

Whether the prosecution proved the guilt of the accused, Reynaldo Aguilar, beyond reasonable doubt for the crimes of Murder and Multiple Attempted Murder.

RULING

The Supreme Court REVERSED the RTC decision and ACQUITTED Reynaldo Aguilar. The Court found the prosecution’s evidence insufficient to prove guilt beyond reasonable doubt. The testimonies of the prosecution witnesses were inconsistent and unreliable. Specifically, Ailleen Aquino’s testimony that she saw the accused immediately after the grenade explosion was contradicted by her earlier statement that she and her family hid in the kitchen and then escaped to the rice paddies without mentioning seeing the accused at that time. The Court also noted that the trial court erroneously relied on Salustiano Aquino’s testimony that he saw the accused shoot the victim, which was not part of the prosecution’s evidence-in-chief but was presented on rebuttal without being covered by the original direct examination. The defense of alibi was strengthened by the lack of positive and credible identification. The Court emphasized that the burden of proof lies with the prosecution, and the evidence failed to meet the required moral certainty for conviction.