G.R. No. 122671 November 18, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO CASTRO, BOY CORTEZ, ARNOLD OLMOS and ROBERTO VINOZA @ “ROBERTO VIOZA,” accused. EDGARDO CASTRO and ROBERTO VINOZA, accused-appellants.

FACTS

Accused-appellants Edgardo Castro and Roberto Vinoza, along with Boy Cortez and Arnold Olmos (at large), were charged with Murder for the killing of Luis Cabantog on October 25, 1990, in Malolos, Bulacan. The prosecution’s main witness was Valentino Fernandez, a friend and gangmate of the accused. He testified that after a drinking spree, the group went to the house of Jasmin Fellas, whom Vinoza was courting. There, they saw the victim talking with Jasmin. After Jasmin went inside and the victim walked towards the fence, the four accused scaled the fence, with Vinoza and Cortez stabbing the victim while Castro and Olmos held his hands. Fernandez, who was outside the fence, witnessed the incident but only reported it to the police on July 11, 1991, claiming he was initially afraid. The defense of the appellants was alibi, with Castro claiming he was at the house of Ligaya Caparas and Vinoza claiming he was at his brother-in-law’s house, both in the same general area, during the incident. The trial court convicted the appellants of Murder, qualified by treachery, and sentenced them to 17 years and 1 day to 20 years of reclusion temporal. The Court of Appeals affirmed the conviction but modified the penalty to reclusion perpetua, then certified the case to the Supreme Court.

ISSUE

Whether the guilt of the accused-appellants for the crime of Murder was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the decisions of the lower courts and ACQUITTED accused-appellants Edgardo Castro and Roberto Vinoza on the ground of reasonable doubt. The Court found the testimony of the sole eyewitness, Valentino Fernandez, insufficient to establish guilt beyond reasonable doubt. Key reasons included: (1) Fernandez’s delay of over eight months in reporting the incident was unjustified, as his claim of fear was belied by his continued association with the appellants afterward and the lack of evidence of any threat; (2) His testimony contained material inconsistencies, such as initially stating he did not know the motive but later claiming it was jealousy, and his description of the weapons used (ice-pick and fan knife) was inconsistent with the medical finding that the wounds could have been inflicted by a single bladed instrument; (3) His credibility was further damaged by his admission on cross-examination that he did not actually see who held the victim’s hands or the actual stabbing, contradicting his direct testimony. The Court held that the prosecution failed to overcome the constitutional presumption of innocence. The defense of alibi, while weak, gained significance due to the unreliability of the prosecution’s evidence. The Court ordered the immediate release of the appellants unless detained for another lawful cause.