G.R. No. L-35914 June 25, 1980
The PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GARLITO ALINDOG, defendant-appellant.

FACTS

The appellant, Garlito Alindog, was charged with robbery with homicide for the alleged carnapping of a jeepney and the killing of its driver, Jaime Caisa, on January 17, 1972. The prosecution’s case rested almost entirely on the testimony of a single eyewitness, Carmelito Caisa, the victim’s nephew. Carmelito initially gave an extra-judicial statement a month after the incident, narrating that four armed men announced a hold-up, ordered the passengers out, and then drove away with the jeepney after a gunshot was heard. In court, however, he added that he actually saw the appellant shoot the driver, a detail absent from his prior statement. The defense presented an alibi, supported by the appellant’s paramour, who testified he was with her at the time of the crime. The defense also highlighted the questionable circumstances of the appellant’s apprehension, not by police but by a local vice-governor, and the lack of any investigative testimony from peace officers.

ISSUE

Whether the guilt of the appellant for the crime of robbery with homicide was proven beyond reasonable doubt.

RULING

The Supreme Court ACQUITTED the appellant. The legal logic centered on the prosecution’s failure to meet the constitutional standard of proof beyond reasonable doubt. The Court found the evidence “quite foggy” and “suspiciously short in important decisive details.” The lone eyewitness testimony was deemed unreliable due to material inconsistencies; his judicial claim of seeing the appellant shoot the driver directly contradicted his earlier extra-judicial statement where he only heard a shot after alighting. The narrative of the crime itself was unclear and illogical, lacking details on how the killing transpired or how the jeepney was driven away after the driver was supposedly shot. The Court also noted the absence of testimony from investigating police officers and the irregular manner of the appellant’s arrest, which further weakened the prosecution’s narrative. While the exact manner of killing need not be proven in robbery with homicide, the evidence must conclusively show the killing occurred on the occasion of the robbery. Here, the totality of the evidence failed to produce moral certainty. The defense alibi, while weak, gained credence in light of the prosecution’s insufficient evidence. Applying the constitutional mandate, the Court resolved all doubts in favor of the accused and ordered his immediate release.