GR 117685; (June, 1999) (Digest)
G.R. No. 117685 June 21, 1999
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFONSO R. BAUTISTA @ “POLDO”, accused-appellant.
FACTS
Accused-appellant Alfonso Bautista was convicted of murder for the killing of Cipriano Bandarlipe. The prosecution’s case rested primarily on the testimonies of the victim’s wife, Leticia Bandarlipe, and a neighbor, Rogelio Peralta. Leticia testified that on a moonlit night illuminated by house lights and a passing payloader, she heard a gunshot and her husband’s shout. She found him wounded and, while embracing him, saw appellant standing two meters away pointing a long firearm. Her dying husband allegedly identified appellant as the assailant. Rogelio Peralta corroborated that he saw appellant carrying a long firearm immediately after hearing the gunshot.
The defense presented a different narrative. Appellant claimed he was framed by Prudencio Feriamil, his employer and the prosecution’s initial suspect. He testified that he had discovered Feriamil and Leticia in a compromising situation, which gave them a motive to implicate him. He further alleged that Feriamil had confessed to the killing in his presence during a confrontation at the barangay hall, a claim supported by the defense witness, Barangay Captain Felipe Solis. Appellant also presented a panty allegedly belonging to Leticia, which he found in Feriamil’s hut, to substantiate their illicit relationship.
ISSUE
Whether the guilt of the accused-appellant for the crime of murder was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted appellant. The Court found the prosecution’s evidence insufficient to establish guilt beyond reasonable doubt. The credibility of the lone eyewitness, Leticia Bandarlipe, was seriously undermined by significant inconsistencies. Her sworn statement given to investigators made no mention of her husband’s alleged dying declaration identifying appellant, a crucial detail she only introduced in her court testimony. This omission cast doubt on the veracity of her account.
Furthermore, the Court found the defense’s theory of frame-up plausible and supported by evidence. The testimony of Barangay Captain Solis, a prosecution witness, lent credence to appellant’s claim that Feriamil had confessed to the crime. The existence of a motive for Feriamil and Leticia to implicate appellant—their fear of exposure for their illicit affair—remained unrebutted by the prosecution. Given these circumstances, the evidence failed to produce the required moral certainty of appellant’s guilt. The constitutional presumption of innocence must prevail where the evidence does not overcome all reasonable doubt.