GR 130889; (June, 2002) (Digest)
G.R. No. 130889 ; June 6, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NORBERTO LORENO, FELIX LEAL, SERAFIN RASCON, JOHN EDWARD LEYSA, and LARRY MOQUERIO, accused. JOHN EDWARD LEYSA, accused-appellant.
FACTS
The prosecution’s case rested primarily on the testimony of Armando Castor, a Civilian Volunteer Organization (CVO) member. He testified that in the early hours of December 26, 1990, in Lambunao, Iloilo, his group leader, Igmedio Larupay, confiscated a firearm from accused Serafin Rascon after a gunshot was heard at a dance. While returning to their detachment, Rascon persuaded Larupay to return to the dance hall to settle the matter. Upon arrival, Castor saw accused Norberto Loreno and appellant John Edward Leysa, with Felix Leal and Larry Moquerio behind them, all armed. Castor claimed he saw both Loreno and Leysa raise their firearms and shoot. He dropped to the ground, and when he looked, Larupay was dead. The necropsy revealed the victim died from a single gunshot wound. The trial court convicted Loreno and Leysa of murder, acquitting the other three accused. Loreno died during appeal, leaving Leysa as the sole appellant.
ISSUE
The core issue is whether the prosecution evidence, particularly the lone eyewitness account of Armando Castor, is sufficient to prove appellant John Edward Leysa’s guilt for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted appellant John Edward Leysa. The Court emphasized that while the testimony of a single witness can be sufficient for conviction if credible, the evidence in this case failed to establish conspiracy beyond reasonable doubt. The prosecution’s narrative showed that both Loreno and Leysa allegedly fired at the victim, yet the medical evidence conclusively proved only one fatal gunshot wound. This critical inconsistency created reasonable doubt as to who actually inflicted the mortal wound.
The legal logic is that for conspiracy to be a basis for collective criminal liability, the prosecution must prove beyond reasonable doubt a unity of purpose and intention among the accused. The mere presence of appellant at the scene and the alleged act of raising a firearm, without clear evidence of a concerted design to kill, is insufficient to establish conspiracy. The paucity of evidence demonstrating a common criminal purpose between Leysa and Loreno meant Leysa’s individual responsibility for the killing was not proven to the required moral certainty. Consequently, the benefit of reasonable doubt inures in favor of the accused, warranting acquittal.