G.R. No. 103395 November 22, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EXEQUIEL ANISCAL, alias Ekil, and MANSUETO REDULLA, alias Chito, accused. MANSUETO REDULLA, accused-appellant.

FACTS

On March 16, 1990, in Maribojoc, Bohol, Juana Bañocia Vda. de Valles was killed during a robbery in her residence. She was found gagged and bound, having died from asphyxia due to suffocation. Cash and jewelry totaling approximately Six Hundred Thousand Pesos (P600,000.00) were taken. An information for Robbery with Homicide was filed against Exequiel Aniscal and Mansueto Redulla. Only Redulla was apprehended and tried, as Aniscal remained at large. The prosecution’s primary witness was Pedro Ramones, who testified that around 9:00 PM on March 16, 1990, he saw Wilfredo Aniscal near the victim’s fence, and shortly thereafter saw Exequiel Aniscal and appellant Mansueto Redulla emerge from the direction of the victim’s house, with Exequiel clutching a dark bag. The three then fled together. The defense presented an alibi, with appellant claiming he was at the Maribojoc Cockfight Arena until about 10:00 PM that evening and then went straight home. The trial court convicted appellant based on circumstantial evidence and sentenced him to Reclusion Perpetua.

ISSUE

Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of accused-appellant Mansueto Redulla for the special complex crime of Robbery with Homicide beyond a reasonable doubt.

RULING

No. The Supreme Court REVERSED and SET ASIDE the trial court’s decision and ACQUITTED accused-appellant Mansueto Redulla. The Court held that the circumstantial evidence was insufficient to produce a moral certainty of guilt beyond reasonable doubt. The requisites for conviction based on circumstantial evidence were not met: (1) there must be more than one circumstance; (2) the inference must be based on proven facts; and (3) the combination of all circumstances must produce a conviction beyond reasonable doubt. The Court found the evidence frail and speculative. The testimony of the lone eyewitness, Pedro Ramones, was deemed unreliable due to inconsistencies (e.g., initially refusing to testify out of fear, then testifying two months later without explanation) and the inherent weakness of his nighttime identification using only a flashlight. The appellant’s alibi was credible and corroborated. Furthermore, the trial court improperly relied on the appellant’s demeanor (e.g., “shifty eyes”) to infer guilt without allowing him to explain. The inculpatory facts were capable of explanations consistent with innocence. Therefore, the prosecution failed to discharge its burden of proof, and the appellant must be acquitted on the ground of reasonable doubt. His immediate release was ordered.