GR 116730; (November, 1995) (Digest)
G.R. No. 116730 November 16, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. WILFREDO DE GUZMAN, accused-appellant.
FACTS
Accused-appellant Wilfredo De Guzman, a tricycle driver, was convicted of Murder for the killing of fellow tricycle driver Diosdado Capurno. The prosecution’s case was built on circumstantial evidence. Witness Jayson Lopez testified that on the night of the killing, he saw the victim’s tricycle hired by Barangay Captain Conrado de Vera and Ismael Ico. Later, he witnessed the victim being mauled and heard gunshots, but he could not identify the assailants in the darkness. Another witness, the victim’s nephew Christopher Capurno, stated that the appellant and the victim had a rivalry over passengers. He also testified that on the morning after the killing, the appellant told him his uncle was dead in the morgue. The prosecution presented a paraffin test indicating nitrates on the appellant’s left hand.
ISSUE
Whether the circumstantial evidence presented by the prosecution is sufficient to prove the guilt of the accused-appellant beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the accused-appellant. The Court held that the totality of the circumstantial evidence failed to meet the required standard of moral certainty for conviction. The evidence did not constitute an unbroken chain leading to the inescapable conclusion of the appellant’s guilt. The testimony of Jayson Lopez did not positively identify the appellant as one of the assailants. The alleged motive of passenger rivalry was weak and insufficient. The paraffin test result was inconclusive, as nitrates can come from substances other than gunpowder, such as fertilizers or tobacco, and the test was only positive on the appellant’s left hand with no evidence he was left-handed. The appellant’s alleged remark to the victim’s nephew was ambiguous and did not imply guilt. While the defense of alibi was weak, the prosecution’s evidence was weaker and failed to overcome the constitutional presumption of innocence. Acquittal was mandated by reasonable doubt.