G.R. No. 72709. August 31, 1989.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO PADILLA, accused-appellant.

FACTS

The accused, Alberto Padilla, was charged with robbery with homicide. The prosecution alleged that on May 16, 1983, in Daram, Samar, Padilla, conspiring with others, boarded a fishing boat, robbed Rogelio Gososo of cash and a wristwatch, and stabbed to death crew member Esteban Labian. The trial court convicted Padilla based on the testimony of Rogelio Gososo, who identified Padilla as the stabber, and the circumstantial evidence of Padilla being found asleep hours later with a bloodstained bolo and blood on his clothing. Padilla was sentenced to reclusion perpetua.
Padilla appealed, denying involvement and presenting an alibi that he was drunk and asleep at home after a picnic. The defense also presented witnesses who testified that another individual, Toto Mendido, had confessed to the killing. The trial court rejected these testimonies as hearsay and not part of the res gestae.

ISSUE

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

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Alberto Padilla. The legal logic centered on the insufficiency of the prosecution’s evidence to overcome the constitutional presumption of innocence. The Court found the identification by Rogelio Gososo unreliable. Gososo testified he was awakened by two men robbing him, with his view obstructed, and only saw the stabbing incident from a distance of about two meters in the darkness, without specifying any identifying marks of the assailant. This identification, made under stressful and poorly lit conditions, lacked the requisite certainty.
Furthermore, the circumstantial evidence was deemed insufficient to support a conviction. The Court held that the bloodstained bolo and clothing, found on Padilla while he was asleep hours after the incident, did not conclusively link him to the crime. No laboratory tests were conducted to match the blood to the victim, and the possibility that the true assailant could have planted the evidence on a drunk and sleeping man was not eliminated. The Court emphasized that for circumstantial evidence to sustain a conviction, the combination of circumstances must produce a moral certainty of guilt and must be inconsistent with any reasonable hypothesis of innocence. Here, the evidence failed this test. The prosecution’s case relied on weak identification and inconclusive physical evidence, which collectively did not establish guilt beyond reasonable doubt. The acquittal was thus ordered, with costs de oficio.