G.R. No. 1289 : January 3, 1905
THE UNITED STATES, complainant-appellee, vs. ANASTASIO BOSITO, ET AL., defendants-appellants.

FACTS:
On November 10, 1902, Eleno Bueno, Macario Aquino, Arcadio Soriano, and Luis Bailen traveled from Santa, Ilocos Sur to Bangued, Abra to purchase hogs. Bueno and Aquino left Bangued on November 12 to return home but never arrived. On November 18, Soriano and Bailen, upon learning of their companions’ disappearance, searched for them. In the barrio of Pugaro, they discovered signs of a struggle, a strong fetid odor, human remains, and blood-stained clothing identified as belonging to Bueno and Aquino. The money the victims carried for purchasing hogs was missing. A complaint for murder and robbery was filed against Anastasio Bosito, Emiliano Berido, Lorenzo Berido, and Peru Princena. During trial, Lorenzo Berido was set for separate trial, Princena was acquitted, and Emiliano Berido was acquitted on final judgment. The trial proceeded against Anastasio Bosito, who was convicted as an accessory after the fact and sentenced to twelve years of imprisonment at hard labor. Bosito appealed.

ISSUE:
Whether the evidence presented by the prosecution is sufficient to prove beyond reasonable doubt that Anastasio Bosito is guilty, either as a principal or as an accessory after the fact, to the crimes of murder and robbery.

RULING:
No. The Supreme Court reversed the judgment of conviction and acquitted Anastasio Bosito.
The Court found that while the circumstances (disappearance, remains, and stolen belongings) sufficiently established that the crimes of murder and robbery were committed against Bueno and Aquino, the evidence linking Bosito to these crimes was insufficient and unreliable. The prosecution’s case hinged on the discovery of two money bags in the possession of Bosito’s wife, one of which was identified as belonging to a victim and had alleged fresh bloodstains. However, the defense successfully presented evidence that Bosito was elsewhere (in the house of Marcos Caballero) on the evening the crimes were believed to have been committed. Furthermore, the defense proved that the money in the bags came from the lawful sale of tobacco and a hog by Bosito and his wife. The Court also noted the improbability that bloodstains would remain “fresh” several days after the crime. The prosecution’s evidence, being weak and contradicted by the defense’s proof of alibi and lawful source of the money, failed to establish Bosito’s guilt beyond reasonable doubt. Consequently, Bosito was acquitted and ordered released. The money and bags seized from his wife were ordered returned to him.