GR 134279; (March, 2001) (Digest)
G.R. No. 134279; March 8, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICKY ROGER AUSTRIA y SACATANE, defendant-appellant.
FACTS
Accused-appellant Ricky Roger Austria was charged with Murder for the stabbing death of Agustin Abad on June 21, 1995, in Manila. The prosecution’s case rested primarily on the testimony of a single eyewitness, thirteen-year-old Rowena Junio. She testified that while walking home at night, she saw three men, including the appellant, accost the victim near a narra tree. She claimed appellant hit the victim with a piece of wood and simultaneously stabbed him, and that she clearly saw his face under a lamppost when he looked around. The medico-legal officer confirmed the victim died from a single, fatal stab wound to the chest. The defense presented an alibi, with appellant testifying he was at home with his family at the time of the incident and only went to the scene after hearing shouts, where he saw the wounded victim but did not initially recognize him.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted the accused-appellant on the ground of reasonable doubt. The Court found the testimony of the lone eyewitness, Rowena Junio, to be replete with material inconsistencies that eroded her credibility. Crucially, she gave conflicting statements regarding her prior familiarity with the appellant. During her direct testimony, she repeatedly stated she saw appellant for the first time during the stabbing incident. However, when confronted with her sworn affidavit executed the day after the crime, she admitted she had known him by face for a long time because he was from the area. This inconsistency, pertaining to a basic fact of identification, cast serious doubt on the reliability of her account.
The Court emphasized that in criminal cases, the burden of proof lies with the prosecution, which must rely on the strength of its own evidence and cannot draw strength from the weakness of the defense. The prosecution’s evidence failed to establish moral certainty of guilt. The weakness of the alibi defense is inconsequential when the prosecution’s evidence is itself weak and unconvincing. Furthermore, the prosecution failed to establish any motive for the killing, which became essential since the identity of the assailant was squarely in question due to the unreliable eyewitness testimony. Applying the constitutional presumption of innocence, all doubts were resolved in favor of the accused-appellant.