G.R. No. L-31694 December 14, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LEONARDO D. ROSALES, alias “NARDING DE ROSALES”, defendant-appellant.

FACTS

On January 29, 1966, a shooting incident occurred during a drinking spree at the Cabay Elementary School in Tiaong, Quezon, resulting in the death of Miguel Hernandez. An information for murder was filed against Leonardo D. Rosales and three others. After trial, the Court of First Instance acquitted the three co-accused but convicted Rosales of murder, sentencing him to life imprisonment. The prosecution’s case relied heavily on the testimonies of three alleged eyewitnesses—Emilio Robles, Virgilio Matuto, and Ireneo Guerra—who initially gave sworn statements that only they, the victim, and Rosales were present at the drinking session and that Rosales was the shooter.
However, significant inconsistencies and new evidence emerged. During the trial, these witnesses recanted their initial affidavits. They testified that they were not actually present at the shooting but were coerced and intimidated by the police into signing the prepared statements. Furthermore, the defense presented evidence that Rosales was elsewhere at the time. A baptismal certificate and testimony from the officiating priest showed Rosales attended a baptism and subsequent celebration in a different barrio on the same afternoon and evening of the crime. The physical evidence was also inconclusive, with recovered slugs from .45 and .30 caliber firearms, while the evidence allegedly linking Rosales was a .38 caliber revolver found with the victim.

ISSUE

The central issue is whether the guilt of appellant Leonardo D. Rosales for the crime of murder was proven beyond a reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Leonardo D. Rosales. The legal logic hinges on the constitutional presumption of innocence and the prosecution’s failure to meet the burden of proving guilt beyond a reasonable doubt. The Court found the evidence against Rosales to be weak, unreliable, and insufficient.
The recantation of the sole eyewitnesses was deemed fatal to the prosecution’s case. Their trial testimony, under oath, revealed that their prior affidavits implicating Rosales were products of police coercion and were not based on personal knowledge. The Court emphasized that affidavits taken ex parte are often inferior to testimony given in open court, where the witness can be cross-examined. When witnesses formally disavow their previous statements under oath, the foundation of the prosecution collapses. Furthermore, the defense of alibi, often viewed with caution, was corroborated by strong and credible evidence—the baptismal certificate and the priest’s testimony—which the trial court erroneously dismissed. This evidence positively placed Rosales at a different location, making his physical presence at the crime scene highly improbable. The Solicitor General’s recommendation for acquittal, acknowledging the duty to protect the innocent, was upheld. Consequently, the Court ruled that the evidence created a reasonable doubt, warranting an acquittal.