G.R. No. L-50631 June 29, 1981
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SALVADOR PERUELO, accused-appellant.

FACTS

On October 19, 1971, tricycle driver Alex de Guzman was found dead in Mangaldan, Pangasinan. The police investigation initially stalled until May 1973, when Demetrio Runez, apprehended in an unrelated operation, executed a sworn statement (Exhibit “E”) implicating himself, Salvador Peruelo, and another individual in the killing and the taking of the tricycle. Based on this, an information for robbery with homicide was filed against Peruelo. The case was archived when Peruelo could not be found. He surfaced in July 1978 when applying for a police clearance. Subsequently, the prosecution presented Federico Moulic, a fishpond caretaker, who claimed to be an eyewitness and identified Peruelo in a police lineup.

ISSUE

Whether the guilt of accused-appellant Salvador Peruelo for the crime charged has been proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction. The prosecution’s case rested primarily on the eyewitness testimony of Federico Moulic, whose identification of Peruelo was deemed extremely tenuous and unreliable. The Court found Moulic’s account, given nearly seven years after the incident, lacked credibility, especially absent any prior report to authorities. Crucially, the prosecution heavily relied on the sworn statement of Demetrio Runez (Exhibit “E”), which was inadmissible as hearsay since Runez was never presented in court for cross-examination. The testimony of the police officer regarding Runez’s statement constituted double hearsay. With the prosecution’s evidence weak, Peruelo’s alibi—that he was in Olongapo City attending his nephew’s birthday, corroborated by his wife, brother, a neighbor, and a birth certificate—gained commensurate strength. The prosecution failed to prove it was physically possible for Peruelo to have been at the crime scene. Consequently, the guilt of the accused was not established beyond reasonable doubt.