GR 140870; (February, 2004) (Digest)
G.R. No. 140870 ; February 11, 2004
PEOPLE OF THE PHILIPPINES, appellee vs. LINO ABUJAN alias “EKE” AND RICHARD VALMORES alias “CARDO,” appellants.
FACTS
Appellants Lino Abujan and Richard Valmores were charged with and convicted of the murder of Reselda Patong by the Regional Trial Court, which imposed the death penalty. The prosecution’s case relied on circumstantial evidence. Witness Victoriano Ramos testified he saw appellants talking with the victim and overheard a brief exchange before he left. Edwin Longakit later saw appellants squatting on the road, with Abujan holding a knife and having bloodstains. Carlito Aguilar testified he was drinking with appellants earlier that day and saw Valmores take a knife, which was later found at the crime scene. The medico-legal officer confirmed the victim suffered multiple stab wounds.
The defense presented alibis and denial. Abujan claimed he was at a purok meeting and later played volleyball during the time of the crime, corroborated by defense witnesses. Valmores similarly denied involvement and claimed he was elsewhere. Both appellants asserted they were arbitrarily arrested and maltreated to extract confessions.
ISSUE
Whether the guilt of the appellants for the crime of murder was proven beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted appellants on the ground of reasonable doubt. The Court emphasized that a conviction based on circumstantial evidence requires that the circumstances constitute an unbroken chain leading to a fair and reasonable conclusion of guilt, to the exclusion of all other hypotheses. Here, the prosecution’s evidence failed to meet this standard.
The testimony of Ramos did not establish that appellants were the perpetrators, as he left before any attack occurred. The bloodstains on Abujan were not forensically linked to the victim. Aguilar’s testimony about the knife was insufficient to prove it was the murder weapon, as no evidence connected it to the wounds besides its recovery at the scene. The alibis, while weak, were corroborated and created reasonable doubt when juxtaposed with the prosecution’s fragile circumstantial chain. The Court held that the evidence did not morally certainty of guilt. In cases involving the capital penalty, doubts must be resolved in favor of the accused. The appellants were ordered released.