G.R. Nos. 135068-72; September 20, 2001
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MAXIMO RAMOS Y SAN DIEGO alias “IMO,” accused-appellant.

FACTS

Accused-appellant Maximo Ramos was charged with two counts of murder for the killings of Eleodoro and Severino Araranggol, and three counts of attempted murder. The incident occurred on February 8, 1997, during a family reunion preparation in Cabanatuan City. At around 8:30 PM, a gunman with shoulder-length hair, a beard, and an earring suddenly appeared and fired an armalite rifle at a group of men drinking, killing the Araranggols and wounding others. The trial court convicted Ramos of murder, imposing the death penalty for each count and civil indemnity, but acquitted him of attempted murder. The prosecution’s case primarily relied on the testimonies of two eyewitnesses, Marcelino Perez and Luis Perez, who identified Ramos in court as the assailant.
Ramos interposed the defense of alibi, claiming he was in a different barangay at the time of the shooting, resting inside his employer’s warehouse with a co-worker. He was later invited for questioning, subjected to a paraffin test which yielded negative results, and identified in a police line-up. He alleged that a policeman, a brother of Marcelino Perez, was gesturing towards him during the line-up. The defense also presented evidence that Ramos was a former CAFGU member issued a Garand rifle, not an Armalite.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, primarily through positive identification.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Maximo Ramos. The Court found the testimonies of the prosecution eyewitnesses unreliable due to material inconsistencies and improbabilities, failing to meet the standard of proof beyond reasonable doubt. Marcelino Perez gave conflicting statements regarding his distance from the gunman and his actions during the shooting, initially claiming he was three meters away and remained seated, but later admitting he was farther and lied face down. His affidavit also omitted his claimed focus on the gunman’s face. Luis Perez’s testimony was deemed doubtful as he claimed to have seen the gunman’s face clearly for about five seconds despite the sudden darkness from a power outage and the assailant’s alleged distinctive facial hair, which was not mentioned in initial investigations.
The Court emphasized that positive identification requires clear and categorical evidence that the accused is the perpetrator. The witnesses’ testimonies did not satisfy this requirement. The defense of alibi, while generally weak, gained strength due to the prosecution’s failure to establish Ramos’s presence at the crime scene convincingly. The negative paraffin test, though not conclusive, was consistent with his denial. The Court reiterated the constitutional presumption of innocence and the principle that it is better to acquit a guilty man than to convict an innocent one when guilt is not proven beyond reasonable doubt. Thus, the decision of the Regional Trial Court was set aside.