G.R. No. L-31084 May 29, 1981
The People of the Philippines, plaintiff-appellee, vs. Westrimundo Tabayoyong alias “Westring”, Eligio Cacayan, Julian Aguilar and Francisco Garlejo, defendants, Antonio Bautista alias “Bucot”, Antolin Castro and Miguel Begenio alias “Aning”, defendants-appellants.

FACTS

The accused were charged with the murder of Barrio Captain Marcelo Guico. The prosecution’s principal witness was Francisco Garlejo, a co-accused who was discharged to become a state witness. Garlejo testified that appellant Westrimundo Tabayoyong offered them a P1,000 reward to kill Guico. After initial reluctance, they were allegedly coerced into agreement by appellant Antonio Bautista. On the night of January 21, 1966, Garlejo, together with appellants Antolin Castro, Miguel Begenio, and Bautista, along with other accused (Eligio Cacayan and Julian Aguilar, who later disappeared), executed the plan. They assaulted Guico with bladed weapons and a piece of bamboo, resulting in his death.
The defense consisted of alibis. Appellants Castro and Begenio claimed they were elsewhere, while Bautista denied involvement and presented witnesses to support his presence at a different location. The trial court convicted all appellants, finding Garlejo’s testimony credible and sufficient to establish conspiracy. The court rejected the alibis for being weak and not physically impossible.

ISSUE

The core issue is whether the testimony of a discharged co-accused, standing alone and uncorroborated, is sufficient to sustain a conviction for murder.

RULING

No, the conviction cannot stand. The Supreme Court reversed the trial court’s decision and acquitted all appellants. The legal logic is anchored on the long-standing rule regarding the testimony of an accomplice. While an accused may be validly discharged to become a state witness under the Rules of Court, his testimony is inherently suspect due to his self-interest in securing immunity or leniency. Jurisprudence consistently holds that the testimony of an accomplice, even if given under oath, is insufficient for conviction unless corroborated in material points by other evidence. The Court emphasized that such testimony, standing alone, is unreliable and untrustworthy.
In this case, the prosecution’s evidence rested almost entirely on Garlejo’s testimony. The autopsy report and other evidence merely established the fact of death, not the identity of the perpetrators. The Court found no substantial corroboration linking the appellants to the crime. The alibis, while not overwhelmingly strong, gained significance in light of the prosecution’s failure to present credible, independent evidence to corroborate the accomplice’s account. Consequently, the evidence did not meet the required proof beyond reasonable doubt. The Court ruled that it is better to acquit a guilty man than to convict an innocent one based on unreliable testimony.