GR 1025; (March, 1903) (Digest)
G.R. No. 1025, March 6, 1903
THE UNITED STATES, complainant-appellee, vs. BONIFACIO PLANA, ET AL., defendants-appellants.
FACTS:
The defendants-appellants, Bonifacio Plana, Emigilio Yadao, and Romualdo Ines, were convicted by the Court of First Instance of Ilocos Norte for the crime of robbery en cuadrilla (robbery by a band). The prosecution stemmed from an incident on the evening of November 21, 1901, where private prosecutor Francisca Guerrero, while traveling by cart on a highway, was allegedly overtaken and robbed by a group of armed men. Guerrero and her companion, Monica Calong, positively identified the three appellants as among the robbers, claiming they had known them from prior social and business dealings. Specifically, Guerrero testified to having recently entered into a failed transaction with appellant Plana for the purchase of a carriage and horses, which led her to believe he bore a grudge against her. The defense presented an alibi supported by numerous witnesses. The driver of the cart, Pedro Juan, provided only a tentative identification of Plana and failed to identify the other two appellants.
ISSUE:
Whether the guilt of the appellants has been proven beyond a reasonable doubt based on the identification by the prosecution witnesses.
RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted the appellants. The Court expressed grave doubt regarding the appellants’ participation in the crime. The identification by the principal witnesses, Guerrero and Calong, was deemed suspicious due to Guerrero’s possible motive to falsely accuse Plana arising from their failed business deal. The Court also found it inherently improbable that Plana, a man of some property known to the victims, would rob them on a clear, moonlit night without disguise. The weak and uncertain identification by the cart driver, Pedro Juan, further undermined the prosecution’s case. In a matter dependent solely on the uncorroborated testimony of a few witnesses, and considering the lack of opportunity for the appellate court to observe witness demeanor, these doubts were resolved in favor of the accused. The case was remanded to the lower court for proceedings consistent with the acquittal.