G.R. No. 138400 ; July 11, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SERGIO CAÑETE, accused-appellant.

FACTS

Sergio Cañete, his three brothers, and their 67-year-old father Sotero were detained at the Liloan, Cebu municipal jail for a murder charge. On June 1, 1997, upon learning they would be transferred to the provincial jail and fearing they would be “salvaged,” they refused to leave their cell, starting a riot. Police used tear gas and water cannons to subdue them. The prosecution alleged that during the melee, Sergio struck his father Sotero on the head with a wooden bunk leg, causing fatal injuries. Sotero later died in the hospital. Sergio was charged with and convicted of parricide by the trial court and sentenced to reclusion perpetua.
Sergio appealed, claiming the trial court erred in finding him guilty beyond reasonable doubt. He presented a different version, asserting that it was actually PO3 Ricardo Enriquez who bludgeoned his father to death. He testified that he and his father were lying prostrate on the cell floor when the police entered and Enriquez clubbed Sotero. This account was corroborated by his sister-in-law, Charito Cañete, and his mother, Florentina.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant, Sergio Cañete, for the crime of parricide beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED Sergio Cañete. The conviction was reversed. The Court found the prosecution’s evidence insufficient to prove guilt beyond reasonable doubt. The core of the prosecution’s case was the testimony of SPO2 Eleazar Salomon, who claimed he saw Sergio strike Sotero. However, the Court found this testimony inherently unreliable and inconsistent with human experience. Salomon testified he was standing outside the cell, looking through a small opening in a metal door during a chaotic riot involving tear gas and a water cannon. The Court deemed it highly improbable that he could have clearly witnessed the specific act inside the crowded, obscured cell. His testimony was also uncorroborated by other police officers present.
Conversely, the defense presented a credible alternative narrative. The testimonies of accused-appellant and his witnesses were consistent and remained unshaken during cross-examination. They provided a plausible explanation for the event, directly contradicting the lone prosecution eyewitness. In criminal cases, the burden of proof lies with the prosecution, which must rely on the strength of its own evidence, not the weakness of the defense. When the prosecution’s evidence fails to meet the required moral certainty and the defense evidence casts reasonable doubt, acquittal is warranted. The evidence created reasonable doubt as to whether Sergio committed the act, and parricide, requiring proof of both the killing and the relationship, was not established beyond reasonable doubt.