G.R. No. 124301 May 18, 1999
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO MELCHOR Y CARIÑO and ORLANDO FARIÑAS, accused, EDUARDO MELCHOR Y CARIÑO, accused-appellant.

FACTS

Accused-appellant Eduardo Melchor and Orlando Fariñas were charged with Murder for the shooting death of Arnold Garingan on January 31, 1994. The prosecution presented eyewitness Aida Guiraban, who testified she saw the two accused running from the victim’s house after hearing gunfire, identifying them by light from a nearby electric post. The police investigation found a hole in the kitchen wall, suggesting the shot was fired from outside. A paraffin test conducted on Melchor yielded a positive result for gunpowder nitrates on his right hand. The defense consisted of alibi, with both accused claiming they were at a medical clinic attending to a relative at the time of the incident, and they presented witnesses to corroborate their presence there.

ISSUE

Whether the guilt of accused-appellant Eduardo Melchor for the crime of Murder has been proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Melchor based on reasonable doubt. The Court found the circumstantial evidence insufficient to form an unbroken chain leading to a conclusion of guilt. The eyewitness identification was deemed unreliable due to the distance, lighting conditions, and the witness’s vantage point, failing to establish positive identification. Crucially, the Court ruled that a positive paraffin test, standing alone, is not conclusive proof that a person fired a gun. Gunpowder nitrates can come from numerous other sources, such as fertilizers, firecrackers, or tobacco. The defense’s alibi, while inherently weak, gained strength due to the prosecution’s failure to present credible evidence placing Melchor at the crime scene. The totality of the evidence did not overcome the constitutional presumption of innocence. The required moral certainty for a conviction was not attained.