GR 109770; (June, 1994) (Digest)
G.R. No. 109770 June 28, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANDION YANGAN, JIMMY YANGAN, JOHN DOE, PETER DOE, RICHARD DOE, and JAMES DOE, accused. ANDION YANGAN and JIMMY YANGAN, accused-appellants.
FACTS
Accused Andion Yangan, Jimmy Yangan, and others were charged with murder for the death of Pepito Castillo on October 15, 1991, in San Isidro, Davao Oriental. Only the Yangan brothers were arrested and arraigned. The prosecution presented witnesses Remelita Pontillas and Maria Pontillas, who testified that at around 2:00 AM, the accused knocked on their door while bringing their hogtied uncle, Pepito Castillo. When the door was not opened, the accused brought Castillo down, built a fire using dried coconut leaves, and then hacked him. The witnesses claimed they recognized the accused by the light of the fire. The defense presented an alibi, stating that both accused were working in Bacong, San Isidro, from October 12 to November 1, 1991. The trial court convicted the Yangan brothers of murder qualified by treachery and sentenced them to reclusion perpetua. The accused appealed, arguing that the prosecution failed to prove their guilt beyond reasonable doubt.
ISSUE
Whether the trial court erred in convicting the accused-appellants despite the prosecution’s failure to prove their guilt beyond reasonable doubt.
RULING
Yes. The Supreme Court reversed the trial court’s decision and acquitted the accused-appellants on the ground of reasonable doubt. The Court found the testimonies of the prosecution witnesses inconsistent and insufficient. Both witnesses, upon questioning by the trial court, admitted they did not actually see the hacking of the victim. Remelita Pontillas stated she only concluded the victim was hacked because of the sound of his moaning. Maria Pontillas also admitted she did not see who hacked the victim because the light was put out. The Court noted that the witnesses’ initial positive declarations were contradicted by their subsequent admissions, casting doubt on their credibility. The alleged spontaneous utterances and circumstances cited by the prosecution were deemed insufficient to establish guilt with moral certainty. The presumption of innocence prevailed, warranting acquittal.