GR 121195; (November, 1996) (Digest)
G.R. No. 121195 November 27, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ENEMESIO ABELLANOSA and CRISANTO ABELLANOSA, JR., defendants-appellants.
FACTS
The accused-appellants, Enemesio Abellanosa and Crisanto Abellanosa, Jr., were convicted of murder for the killing of Barangay Captain Maximo Abadies. The prosecution’s case rested primarily on the testimonies of two alleged eyewitnesses, Crispulo Sanchez and Victoriano Damas, who were with the victim guarding a cornfield. They testified that at night, they saw the appellants and an unidentified companion approach the sleeping victim. Enemesio shot the victim multiple times, after which Crisanto, Jr. fired the victim’s rifle into the air. The witnesses claimed they remained silent and motionless until morning. Their initial statements to the police denied knowledge of the perpetrators, and they only identified the appellants later. The prosecution also relied on a paraffin test positive for nitrates on the appellants and witness Sanchez.
The defense presented alibis, with Enemesio claiming he was at a wake and Crisanto, Jr. asserting he was at home. They challenged the credibility of the eyewitnesses, highlighting the unnatural behavior of remaining inert for hours after witnessing a brutal killing, the initial denial to authorities, and the weak corroborative value of the paraffin test, which is inconclusive for determining recent gunpowder residue.
ISSUE
Whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the appellants. The prosecution failed to discharge its burden of proof. The Court found the testimonies of the principal witnesses inherently unbelievable. Their claim of remaining squatting and unmoving for over five hours after the shooting, without alerting anyone, defied human experience and natural instinct. Their initial denial to investigators further eroded their credibility. The paraffin test results were unreliable for conviction, as they could indicate contact with substances other than gunpowder from a recent firearm discharge. The constitutional presumption of innocence must prevail when the prosecution’s evidence is weak and fails to meet the required moral certainty. The prosecution must rely on the strength of its own evidence, not on the weakness of the defense. Since the evidence engendered more doubt than certainty, a mandatory acquittal was warranted.