GR 130683; (May, 2000) (Digest)
G.R. No. 130683. May 31, 2000.
ELIGIO MADRID, petitioner, vs. COURT OF APPEALS, REGIONAL TRIAL COURT and PEOPLE OF THE PHILIPPINES, respondents.
FACTS
Petitioner Eligio Madrid and Arsenio Sunido were charged with homicide for the killing of Angel Sunido on May 21, 1992, in Buguey, Cagayan. The prosecution alleged that after a quarrel over a fighting cock, Angel was attacked by his brother Arsenio, with Madrid and another companion holding Angel’s arms to facilitate the stabbing. The prosecution’s case primarily rested on the testimonies of the victim’s wife, Remedios Sunido, and daughter, Merdelyn Sunido. Their affidavits and court testimonies described Madrid’s direct participation by holding the victim. The medico-legal officer testified that the multiple stab wounds could have been inflicted by more than one assailant.
The defense presented a different account. Witness Jerry Escobar testified that he was with the victim drinking until noon and that the fatal altercation occurred later, around 2:00 PM, solely between the Sunido brothers, with no participation from Madrid. Both Madrid and Arsenio Sunido testified that Madrid was at his rice mill at the time of the incident and only learned of the killing afterwards. They asserted that Madrid had no motive to kill Angel and that the charge stemmed from a family grudge.
ISSUE
Whether the prosecution proved beyond reasonable doubt that petitioner Eligio Madrid conspired with Arsenio Sunido in killing Angel Sunido.
RULING
No. The Supreme Court reversed the conviction and acquitted Eligio Madrid. The Court found the prosecution evidence insufficient to prove conspiracy or direct participation. The testimonies of the principal witnesses, Remedios and Merdelyn Sunido, were replete with material inconsistencies and irreconcilable contradictions regarding Madrid’s alleged act of holding the victim. Their affidavits and court declarations conflicted on critical details, such as the number of assailants, the manner of restraint, and the sequence of events. The Court emphasized that for conspiracy to exist, there must be credible proof of a common criminal design; mere presence at the scene is not enough.
The medico-legal testimony was inconclusive, as the doctor admitted the wounds could have been inflicted by one person using one weapon. The defense of alibi, coupled with the lack of motive and the positive testimony of disinterested witness Jerry Escobar, cast reasonable doubt on Madrid’s guilt. The Court ruled that the prosecution failed to meet the required quantum of proof, as the evidence did not sustain a moral certainty of Madrid’s criminal liability. Conspiracy must be proven as clearly as the crime itself, which was not done in this case.