G.R. No. 129220; September 6, 2000
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SPO1 BERNIE JAMON FAUSTINO, accused-appellant.

FACTS

The Regional Trial Court convicted SPO1 Bernie Jamon Faustino of robbery with homicide for his alleged participation in the robbery of BPI Family Bank, Parañaque, on March 11, 1996, and the killing of Police Inspector Florendo Escobar during its commission. The prosecution presented witnesses who testified to the robbery and subsequent shootout. Dante Inting, a key witness, claimed he saw accused-appellant at the scene firing an M-203 grenade launcher and shooting at responding policemen, including the victim. However, Inting did not disclose this identification to authorities until March 25, 2000, years after the incident, citing a threat from a certain Ritchie Ylaya as his reason for the delay.
The defense presented an alibi, corroborated by five witnesses, including police officers and barangay officials. They testified that accused-appellant was attending a barangay meeting in Manila at the time of the crime, from 10:00 a.m. to 3:00 p.m., and could not have been at the robbery site in Parañaque. The defense also challenged the reliability of the cartographic sketch used to identify Faustino, noting that the eyewitnesses who supposedly described the gunman to the sketch artist were never presented in court.

ISSUE

Whether the prosecution proved the guilt of accused-appellant beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant. The Court found the prosecution’s evidence insufficient to establish guilt beyond reasonable doubt. The identification by Dante Inting was deemed unreliable due to its inordinate delay of four years without a satisfactory explanation, as the alleged threat from Ylaya was not substantiated. The Court emphasized that delayed disclosures, unless reasonably justified, cast serious doubt on their credibility.
Furthermore, the prosecution failed to present the eyewitnesses who allegedly provided the description for the cartographic sketch. The Court ruled that a sketch alone, without the testimony of the describing witnesses, is inadmissible and cannot sustain a positive identification. While alibi is generally a weak defense, it gains strength when, as here, the prosecution’s evidence on identification is feeble. The defense alibi was corroborated by multiple disinterested witnesses, creating reasonable doubt. The Court held that when the evidence for the prosecution is weak, the defense need not even present evidence. The constitutional presumption of innocence must prevail, and any doubt is resolved in favor of the accused.