G.R. No. 115006 March 18, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GREGORIO MARCOS @ JUNIOR, accused-appellant.

FACTS

The prosecution charged Gregorio Marcos with murder for the stabbing death of Vicente Reyes on March 30, 1988, in Ramon, Isabela. The primary eyewitness, Petronilo Jacinto, testified that he saw the accused-appellant and two others holding the deceased while the latter was being stabbed inside a restaurant. However, Jacinto’s testimony was inconsistent; in his sworn statement, he claimed only one of five assailants stabbed the victim, and he admitted he could not clearly see the stabbing itself due to the commotion. He also stated he had never seen the accused before the incident and only identified him two years later in court. The restaurant owner, Geronima Barbero, testified that the accused was present in her eatery drinking with others before the incident but did not witness the stabbing, having left minutes before it occurred.
The defense presented an alibi, with the accused-appellant claiming he was in a different barangay at the time. The trial court convicted Marcos of murder, finding the eyewitness identification credible and rejecting the alibi. The court sentenced him to reclusion perpetua and ordered him to pay damages.

ISSUE

Whether the guilt of the accused-appellant for the crime of murder was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Gregorio Marcos. The Court held that the prosecution failed to prove his guilt beyond reasonable doubt. The eyewitness identification by Petronilo Jacinto was deemed unreliable due to material inconsistencies between his court testimony and his prior sworn statement, particularly regarding the number of assailants and who actually inflicted the stab wound. His claim of seeing the accused holding the victim for 20 seconds was also questionable given his admission of a obstructed view and the sudden, chaotic nature of the event. The testimony of Geronima Barbero merely placed the accused at the scene earlier but did not prove his participation in the killing. Crucially, the prosecution failed to establish conspiracy between the accused and the actual perpetrators. His mere presence at the location, without proof of a common criminal design, is insufficient for criminal liability. The evidence presented was capable of two interpretations: one consistent with guilt and another consistent with innocence. When inculpatory facts do not meet the test of moral certainty, the presumption of innocence must prevail. The weakness of the defense of alibi becomes irrelevant when the prosecution itself does not overcome the burden of proof.