G.R. No. 126050. January 16, 2001.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SPO2 ELEAZAR M. MADALI, SPO2 EUSTAQUIO V. ROGERO, and SPO1 RANDY M. RUBIO, accused-appellants.

FACTS

Accused-appellants, all members of the PNP, were convicted by the Regional Trial Court of Romblon for the murder of Reynaldo Abrenica and sentenced to reclusion perpetua. The prosecution’s case relied heavily on the testimony of eyewitness Mercy Villamor. She testified that on the night of February 4, 1992, she saw appellants Madali and Rogero forcibly take Abrenica from a store. Later, she allegedly saw Madali punch Abrenica, after which Rubio struck him on the head with a stone, causing him to fall. The appellants then purportedly carried the unconscious victim to his house and placed him on the stair landing to simulate an accidental fall.
The defense presented a different account. Appellants testified they were on patrol and merely responded to a commotion, finding Abrenica already injured from a fight with another individual. They claimed they helped carry him home. The defense also highlighted the initial belief of the victim’s wife, Helen, that her husband died from an accidental fall, as there was no blood at the scene where she found him.

ISSUE

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

RULING

The Supreme Court REVERSED the conviction and ACQUITTED the accused-appellants on the ground of reasonable doubt. The Court found the testimony of the lone eyewitness, Mercy Villamor, insufficient to sustain a conviction. Her testimony was riddled with inconsistencies and improbabilities. Crucially, her account of the violent assault—involving a blow to the head with a stone—was irreconcilable with the physical evidence. The autopsy report showed no skull fracture or severe cranial injury that such an attack would typically cause; the cause of death was cerebral edema and congestion. Furthermore, the victim’s body, as found by his wife, showed no traces of blood, which contradicted a violent bludgeoning.
The Court also noted the witness’s prior inconsistent statement given during the preliminary investigation, which she lamely excused. The prosecution failed to establish the qualifying circumstance of treachery, as the alleged provocative remark from the victim negated the element of surprise. Given the unreliable eyewitness account, the lack of corroborating physical evidence, and the existence of another plausible explanation for the death, the evidence did not meet the required moral certainty for conviction. The presumption of innocence prevailed.