GR 75028; (November, 1991) (Digest)
G.R. No. 75028 . November 8, 1991.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. PIOQUINTO DE JOYA y CRUZ, defendant-appellant.
FACTS
Appellant Pioquinto de Joya was convicted of robbery with homicide for the death of 88-year-old Eulalia Diamse and the taking of jewelry valued at P550.00. The prosecution’s case rested primarily on circumstantial evidence. A neighbor saw appellant holding a bicycle in the victim’s yard around the time of the incident. The victim’s grandson, Alvin, found her mortally wounded. Before she died, she held his hand and uttered “Si Paqui,” allegedly referring to appellant. Investigation revealed missing jewelry and a ransacked house. The defense presented alibi, claiming appellant was elsewhere during the incident.
The trial court convicted appellant, sentencing him to life imprisonment. It considered the dying declaration and circumstantial evidence as sufficient proof beyond reasonable doubt. The court also noted several aggravating circumstances but could not impose the death penalty due to appellant’s age (72). Appellant appealed, arguing the evidence was insufficient for a conviction.
ISSUE
Whether the prosecution proved appellant’s guilt for the crime of robbery with homicide beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted appellant on grounds of reasonable doubt. The Court scrutinized the two key pieces of evidence. First, the alleged dying declaration (“Si Paqui”) was deemed incomplete and unreliable. The utterance, without more, did not clearly identify the assailant or describe any criminal act, failing to meet the required explicitness for admissibility. Second, the circumstantial evidence—the neighbor’s sighting and the missing items—did not constitute an unbroken chain leading to the sole conclusion of appellant’s guilt. Other inferences were possible.
The Court also addressed the prosecution’s claim of an implied admission of guilt from an alleged offer to compromise. It found the testimony on this point insufficiently explicit to justify such an inference for a serious non-compoundable crime. The totality of the evidence failed to produce the moral certainty required for a criminal conviction. The conscience of the Court remained unsettled, warranting acquittal based on reasonable doubt.