GR 108454; (March, 1997) (Digest)
G.R. No. 108454 March 13, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. TEDDY QUINAO, ROLANDO SIDRO and BALTAZAR ORTIZ, respondent-appellants.
FACTS
Accused-appellants Teddy Quinao, Rolando Sidro, and Baltazar Ortiz were charged with murder for the killing of Cecilio Magpantay. The prosecution’s case relied primarily on the eyewitness account of the victim’s wife, Teresita Magpantay. She testified that on the evening of September 14, 1991, Quinao and Sidro barged into their house, with Quinao shooting her sleeping husband in the face. Sidro then pointed a gun at her. Subsequently, Ortiz and another companion entered the house by jumping over sacks of rice before all four fled. This account was corroborated by witnesses Rizalito Basa and Reynaldo Ancheta, who heard gunshots and saw the three accused running from the scene.
The defense interposed alibi and denial. Quinao and Ortiz claimed they were in Lapinig, Samar, at the time of the crime, while Sidro alleged he was in Valenzuela but at a different location. They asserted they were framed by the police. The trial court convicted all three accused of murder and sentenced them to reclusion perpetua, prompting this appeal questioning the sufficiency of the prosecution’s evidence.
ISSUE
Was the prosecution evidence sufficient to prove the guilt of the accused beyond reasonable doubt?
RULING
The Supreme Court affirmed the conviction of Quinao and Sidro but acquitted Ortiz. The Court reiterated that alibi and denial are inherently weak defenses and cannot prevail over the positive identification by credible witnesses. Teresita Magpantay’s testimony was found to be clear, consistent, and credible, as she had a direct and unobstructed view of the assailants in her well-lit house. Her account was materially corroborated by the testimonies of Basa and Ancheta, who placed the accused fleeing the crime scene.
However, the Court acquitted Ortiz due to insufficient proof of conspiracy. Conspiracy must be proven as convincingly as the crime itself. The evidence showed Ortiz entered the house only after the fatal shot was fired by Quinao. His mere presence at the scene, without proof of any prior agreement or concerted action to kill the victim, did not establish conspiracy. His act of jumping over the sacks to enter did not, by itself, demonstrate a shared criminal intent with the triggerman. Consequently, while the prosecution proved the individual liability of Quinao as the shooter and Sidro as a conspirator who provided support by intimidating the witness, it failed to meet the quantum of proof needed to establish Ortiz’s participation in the conspiracy to commit murder.