GR 2880; (January, 1907) (Digest)
G.R. No. 2880
THE UNITED STATES, plaintiff‑appellee, vs. MARIANO MARCIAL, ET AL., defendants‑appellants
FACTS
On the night of 25 February 1905 a group of four or five robbers boarded the sailing vessel Celeste Burrill anchored in Manila harbor. They violently seized ₱180 and other personal property belonging to the captain, Gregorio Llorca, and murdered him with bolos and daggers. The trial court convicted Mariano Marcial, Ramon Balboa, Diego Ampero (alias Diego Alfaro), and Juan Huertas of robbery with homicide and sentenced each to death.
Evidence:
– A woman passenger, the sole eyewitness, positively identified Marcial, Balboa, and Huertas as participants; she did not identify Ampero.
– No other witnesses could identify Marcial or Balboa. Their identification rested solely on the woman’s uncorroborated testimony.
– Huertas was linked to the crime by the same eyewitness and by the discovery of a silver watch bearing Llorca’s name, which Huertas had left for repair the night after the robbery.
– Ampero’s alleged link rested on the testimony of co‑accused Diego Pastrana (who had been dismissed as a defendant to serve as witness) and on an alleged confession obtained at the police station. Pastrana’s statements were inconsistent and uncorroborated; the purported confession was excluded for lack of proper corroboration and procedural defects.
ISSUE
Whether the convictions of Marcial, Balboa, and Ampero for robbery with homicide were supported by evidence proving guilt beyond reasonable doubt, given the reliance on uncorroborated identification and a discredited confession.
RULING
The Supreme Court held that:
1. The convictions of Marcial and Balboa cannot be sustained. Their sole linkage to the crimeidentification by a single eyewitness who had no prior acquaintance with themwas uncorroborated and insufficient to meet the constitutional standard of proof beyond reasonable doubt.
2. The conviction of Ampero is likewise untenable. The testimony of Pastrana was unreliable, and the alleged confession was inadmissible due to procedural irregularities and lack of corroboration. Accordingly, no proof beyond reasonable doubt existed.
3. The conviction of Huertas is affirmed. In addition to the eyewitness identification, the presence of the captain’s engraved watch in Huertas’s possessionvalidated by the jeweler’s receiptcorroborated his participation, satisfying the evidentiary threshold.
Accordingly, the Court reversed the judgments and death sentences of Marcial, Balboa, and Ampero, ordering their immediate release and awarding them the proportionate share of costs in both instances. The judgment and sentence against Huertas were affirmed, with his proportionate costs assessed. The record was to be returned to the trial court for compliance with the decree.
