G.R. No. 139670; January 21, 2002
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AHMAD LANGALEN y DEMALEN a.k.a. “KUMANDER KAMLON,” HASIM UPAM y ABUBACAR, SAMSUDIN TALIB y LIMBA, and ABUBAKAR DAGADAS y ANGGUBALA, accused-appellants.

FACTS

On September 8, 1995, a convoy of four vehicles carrying over thirteen million pesos for VMG Money Changer was ambushed along Palacio Street, Intramuros, Manila. Gunmen in fatigue uniforms opened fire, killing a police escort and wounding several others before carting away the money. The National Bureau of Investigation (NBI) identified suspects through information from a common-law wife, Halina Gulam, leading to the arrest of Mohamad Mamison. After interrogation, Mamison implicated the four accused-appellants—Ahmad Langalen, Hasim Upam, Samsudin Talib, and Abubakar Dagadas—as participants. They were later arrested in a raid on Langalen’s house for illegal possession of firearms and were positively identified by Mamison in a police line-up. The trial court convicted them of violating the Anti-Piracy and Anti-Highway Robbery Law (P.D. No. 532) and sentenced them to death.
The defense presented alibis, with each accused-appellant claiming to be elsewhere during the incident. Langalen and Upam asserted they were in Taguig, Talib claimed he was in Cotabato City, and Dagadas stated he was in Zamboanga. Their alibis were corroborated by several disinterested witnesses. The defense also challenged the credibility of Mamison, the sole eyewitness, arguing his testimony was inconsistent and given under the NBI’s witness protection program, which may have influenced his cooperation.

ISSUE

Whether the guilt of the accused-appellants was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED the accused-appellants. The Court held that the prosecution failed to establish their guilt with the required moral certainty. The conviction relied heavily on the uncorroborated testimony of Mamison, a confessed co-conspirator. His testimony was deemed inherently suspect, as it came from a polluted source and lacked independent corroboration. The Court emphasized that the testimony of an accomplice must be received with caution and is insufficient for conviction unless corroborated by other evidence. No such corroborative evidence was presented. Furthermore, the trial court erred in dismissing the defense of alibi without proper consideration. The alibis were physically possible and supported by credible witnesses, creating reasonable doubt. The Court ruled that when an alibi is plausible and the prosecution’s evidence is weak, the constitutional presumption of innocence must prevail. The gravity of the offense and the imposition of the death penalty demanded the highest standard of proof, which was not met.