G.R. No. 130652 June 21, 1999
People of the Philippines vs. Noel Diaz y Santiago @ Boy Topak

FACTS

The accused-appellant, Noel Diaz, was convicted by the Regional Trial Court of Kidnapping a minor and sentenced to reclusion perpetua. The prosecution alleged that on June 3, 1996, in Malabon, Metro Manila, Diaz, with an unidentified companion, abducted five-year-old Maylin Maribujo. The state’s case rested primarily on the testimony of an 11-year-old eyewitness, Marvin Bisana, who claimed he saw Diaz take the child. The victim was recovered days later from two women in Valenzuela. The defense presented an alibi, claiming Diaz was elsewhere during the incident.

ISSUE

Whether the guilt of the accused-appellant was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted Noel Diaz. The Court emphasized that while trial courts are generally accorded deference in assessing witness credibility, this rule is not absolute. The prosecution’s evidence was replete with material and pervasive inconsistencies that, taken together, created reasonable doubt. Key inconsistencies involved the timeline of the eyewitness’s report to the victim’s mother and his sworn statement regarding his pursuit of the accused. Furthermore, the testimony of another prosecution witness, Dolores Santos, who found the child, did not positively identify Diaz as the man she saw with the child. The prosecution failed to establish the essential element of intent to deprive the victim of her liberty, as the evidence did not convincingly show that Diaz carried the child away against her will. The Court reiterated that the burden of proof lies with the prosecution, which must rely on the strength of its own evidence and not on the weakness of the defense. The totality of the inconsistencies and gaps in the prosecution’s narrative rendered its case insufficient to meet the quantum of proof required for a criminal conviction.