G.R. No. 121193 January 22, 1998
People of the Philippines, plaintiff-appellee, vs. Ambitonio Palma Gil, accused-appellant.

FACTS

An Information was filed on September 8, 1992, accusing Ambitonio Palma Gil of murder for stabbing Valeriano O. Martin on June 4, 1992, in Samal, Davao. The prosecution’s evidence, received by Judge Mariano C. Tupas, consisted primarily of the eyewitness accounts of Bonifacio Martizano and his 14-year-old son, Jorry. They testified that at around 4:00 a.m., while returning from fishing, they saw the accused stab the victim in the back from a distance of three fathoms. The accused then paddled away. The victim’s wife, Serafia Martin, was informed of the incident and saw the stab wound. The police, after investigation, arrested the accused at his house. The defense, whose evidence was received by the succeeding Judge Bernardo Saludares, presented an alibi. The accused, along with witnesses Crispin Casinto and Agoncillo Mamontong, claimed they were on duty as members of the Bantay Dagat in Tagpopong, Babak, Davao, from 3:00 a.m. to 7:00 a.m. on June 4, 1992. The trial court convicted the accused of murder, giving credence to the prosecution witnesses, finding the alibi weak, and considering an alleged settlement attempt as an implied admission of guilt. The accused was sentenced to reclusion perpetua and ordered to pay damages.

ISSUE

1. Whether the trial court erred in giving full weight and credence to the testimonies of the prosecution witnesses despite alleged inconsistencies.
2. Whether the trial court erred in convicting the accused-appellant despite the alleged failure of the prosecution to prove his guilt beyond reasonable doubt.
3. Assuming guilt, whether the trial court erred in convicting the accused of murder instead of homicide due to lack of proof of treachery.

RULING

The Supreme Court ACQUITTED accused-appellant Ambitonio Palma Gil and SET ASIDE the decision of the Regional Trial Court.
1. The Court found material inconsistencies in the testimonies of the eyewitnesses, Bonifacio and Jorry Martizano, which cast doubt on their presence at the crime scene. These included discrepancies on whether they were paddling or rowing their boat, the position of the petromax lamp, and their actions immediately after witnessing the stabbing. The Court also noted it was improbable for the accused to stab the victim in a well-lighted area with other fishermen present and then be found unperturbed at home the next day.
2. The prosecution’s evidence failed to establish guilt beyond reasonable doubt. The Court highlighted the weakness of the identification, the questionable nature of the alleged settlement offer (which was not directly made by the accused but by a third party, Datu Dawang), and the fact that the eyewitnesses were relatives of the victim (Bonifacio was married to the sister of the victim’s wife, and the victim was Jorry’s uncle), necessitating strict scrutiny of their testimonies. The Court also noted that the judge who penned the decision did not hear the prosecution witnesses, relaxing the general rule of deference to trial court credibility assessments.
3. Given the acquittal, the Court did not reach the third issue regarding the proper classification of the crime. The acquittal was based on the failure of the prosecution evidence to meet the required standard of proof beyond reasonable doubt.