GR 105388; (November, 1994) (Digest)
G.R. No. 105388 November 18, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONIZA VILLAGONZALO and RENITO MORO, accused-appellants.
FACTS
Accused-appellants Leoniza Villagonzalo, the common-law wife of the victim Ricardo Tan, and Renito Moro, their tenant, were charged with murder for the killing of Tan. The prosecution’s case rested primarily on the testimonies of two witnesses, Presilla Villarin and Tito Alquizar, who were domestic helpers in the Tan household. They testified that on August 16 and 17, 1990, they witnessed appellants conspiring with two other individuals, Bano dela Cruz and Joyjoy Asentista (who remained at large), to kill Tan. They alleged that Villagonzalo offered P10,000.00 for the killing, that Moro delivered a firearm to the hired killers upon Villagonzalo’s instruction, and that Alquizar later handed over P2,000.00 to the killers immediately after the shooting. The trial court convicted both appellants of murder and sentenced them to reclusion perpetua.
ISSUE
Whether the guilt of the accused-appellants was proven beyond reasonable doubt based on the testimonies of the prosecution witnesses.
RULING
No. The Supreme Court reversed the conviction and acquitted the accused-appellants. The Court found the testimonies of the principal prosecution witnesses, Villarin and Alquizar, to be inherently incredible and contrary to human experience. Their detailed account of the conspiracy—where the appellants allegedly openly discussed the murder plot and the payment of reward money in the presence of mere helpers—defies belief. It is unnatural for conspirators to reveal their criminal plans to non-participants who were not shown to be trusted confidants. Furthermore, the witnesses’ claim that Alquizar was instructed to hand payment to the killers immediately after the gunshots, while the victim was still alive and other household members were present, is implausible. The Court emphasized that while the trial court’s assessment of witness credibility is generally respected, it is not absolute, especially when the testimony is improbable on its face. The evidence failed to overcome the constitutional presumption of innocence. The prosecution’s case, built solely on these dubious testimonies without corroboration, did not meet the required proof beyond reasonable doubt.