G.R. No. 175195 , September 15, 2010
VIRGILIO BUG-ATAN, BERME LABANDERO, and GREGORIO MANATAD, Petitioners, vs. THE PEOPLE OF THE PHILIPPINES, Respondent.

FACTS

Petitioners Virgilio Bug-atan, Berme Labandero, and Gregorio Manatad were charged with Murder for the death of Pastor Papauran on April 15, 1993. The prosecution’s case rested primarily on the extrajudicial confession and testimony of Norman Maramara, who had already been convicted of Homicide for the same killing via plea bargaining. Maramara testified that on April 14, 1993, petitioners Manatad and Bug-atan instructed him to kill the victim, provided him with a .38 caliber revolver and money, and promised him P30,000.00 and assistance in a pending murder case. The following day, Maramara, accompanied by petitioner Labandero, proceeded to the victim’s house in Mandaue City where Maramara shot Pastor Papauran. Bug-atan allegedly acted as a back-up, waiting nearby on his motorcycle.
The petitioners denied the accusations. Manatad interposed alibi, claiming he was in different towns in Cebu province at the time. Labandero asserted he was in Manila, having fled due to death threats after testifying against Maramara in a previous case, and alleged Maramara’s testimony was a fabricated act of revenge. Bug-atan simply denied any participation. The Regional Trial Court found them guilty of Homicide, a decision affirmed by the Court of Appeals.

ISSUE

Whether the conviction of the petitioners based primarily on the uncorroborated testimony of their alleged co-conspirator, Norman Maramara, is valid.

RULING

No. The Supreme Court acquitted the petitioners. The Court reiterated the established rule that the testimony of a co-conspirator, while admissible, is inherently suspect and insufficient for conviction unless corroborated by other evidence. An exception exists where the testimony is given in a straightforward manner and contains details that could not be the result of deliberate afterthought. The Court found that Maramara’s testimony did not qualify for this exception. His narration was not spontaneous and replete with details; instead, it was vague, inconsistent, and failed on crucial points such as the specific roles of each petitioner and the alleged promise of legal assistance for his pending case. His testimony was also deemed unreliable as it was given after he had entered a plea bargain, creating a motive to implicate others to mitigate his own liability.
The Court emphasized that the burden of proof lies with the prosecution to establish guilt beyond reasonable doubt. The prosecution failed to present any independent evidence to corroborate Maramara’s claims. The petitioners’ defenses of alibi and denial, while inherently weak, gain strength in light of the prosecution’s failure to discharge its burden. Consequently, the evidence presented did not overcome the constitutional presumption of innocence. The conviction was reversed, and petitioners were ordered acquitted and immediately released.