G.R. No. L-22295 January 30, 1970
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PRUDENCIO MADARANG, defendant-appellant.
FACTS
On the night of April 22, 1963, Jose Abella was alone in his house in Barrio Macalang, Dasol, Pangasinan. Neighbors heard his cries for help and found him with a fatal gunshot wound between the anus and testicles. The medico-legal report indicated death from shock due to massive internal hemorrhage. A slug was found but later lost. A complaint for murder was filed against Prudencio Madarang on May 28, 1963. The prosecution presented witnesses Ricardo Villanueva and Anselmo Villaruz, who claimed to have seen the accused near the scene. Villanueva testified he saw Prudencio Madarang peep into the house and fire a shot, then flee with his brother Leoncio. Villaruz testified he heard a gunshot and saw the accused and his brother running. Both witnesses did not report their accounts immediately; Villanueva initially told investigators he knew nothing, and Villaruz claimed he only learned of the death in July. The trial court found these witnesses not credible. The prosecution also presented circumstantial evidence through Crisostomo Molino, Pedro Abella, Ambrosio Ramirez, and Venancio Mirador, detailing suspicious statements and behavior by the accused, such as objecting to superstitious burial practices, expressing a desire to surrender to protect family members, and later requesting witnesses not to testify. The accused denied all allegations and presented an alibi that he was away peddling mangoes from April 20 to 23.
ISSUE
Whether the evidence presented by the prosecution, both direct and circumstantial, is sufficient to prove the guilt of the accused beyond reasonable doubt.
RULING
No. The Supreme Court reversed the trial court’s judgment and acquitted the accused. The Court held that the direct eyewitness accounts of Ricardo Villanueva and Anselmo Villaruz were not credible due to their belated revelations and inconsistencies. The circumstantial evidence, even if assumed true, did not produce a conviction beyond reasonable doubt as it was consistent with both guilt and innocence. The combination of circumstances failed to meet the requisite moral certainty for conviction. The Court emphasized that when inculpatory facts are capable of two explanations, one consistent with innocence, the evidence does not support conviction. Consequently, the accused was acquitted.
