GR 205745; (March, 2017) (Digest)
G.R. No. 205745 March 8, 2017
Capistrano Daayata, Dexter Salisi, and Bregido Malacat, Jr., Petitioners vs People of the Philippines, Respondent
FACTS
Petitioners were charged with Frustrated Murder for an attack on Rolando Bahian on December 17, 1995, stemming from a prior altercation during a basketball game. The prosecution, through Bahian and Kagawad Leonardo Abalde, alleged that while Bahian and Abalde were on their way to report the prior incident to the barangay captain, petitioners blocked their path. Daayata first struck Bahian, after which Salisi hit him on the head with a stone, causing him to fall. Petitioners then collectively boxed and kicked Bahian while he was defenseless on the ground. The prosecution further claimed Daayata poked a gun and Malacat unsheathed a bolo during the assault. The timely intervention of Barangay Captain Yafiez stopped the attack, and Bahian survived after undergoing surgery for a depressed skull fracture.
The defense presented a contrary narrative. Petitioners Salisi and Malacat claimed they were at a house when Bahian arrived, challenged Salisi to a fight, and threw the first punch. During the ensuing scuffle, Bahian lost his balance, fell, and hit his head on the pavement. They asserted that it was Kagawad Abalde who brandished a gun. Petitioner Daayata claimed he arrived later to find Abalde pointing a gun at Malacat. The Regional Trial Court and the Court of Appeals convicted petitioners of frustrated murder, prompting this appeal.
ISSUE
Whether the prosecution proved the guilt of the petitioners for the crime of frustrated murder beyond reasonable doubt.
RULING
No. The Supreme Court acquitted the petitioners. The prosecution failed to discharge its burden of proving guilt beyond reasonable doubt. The Court found the testimonies of the prosecution witnesses, particularly Bahian and Kagawad Abalde, to be inconsistent and unreliable on material points. Critical details, such as the exact location of the initial confrontation and the sequence of events involving the use of weapons (stone, gun, bolo, iron bar), were riddled with contradictions between their accounts and their prior sworn statements. The Court emphasized that the conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. When the prosecution’s evidence is fraught with inconsistencies that cast doubt on the very occurrence of the crime as alleged, the accused must be acquitted. The evidentiary burden was not met, creating reasonable doubt as to whether the petitioners committed the aggravated assault described by the prosecution. Consequently, the presumption of innocence prevails.