GR 80762; (March, 1990) (Digest)
G.R. No. 80762 March 19, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FAUSTA GONZALES, et al., accused, CUSTODIO GONZALES, SR., accused-appellant.
FACTS
The accused, including appellant Custodio Gonzales, Sr., were convicted of murder for the killing of Lloyd Peñacerrada. The prosecution’s case relied heavily on the testimony of Jose Huntoria, who claimed he witnessed the incident. Huntoria testified that on the night of February 21, 1981, he saw the appellant and his co-accused attack the victim inside a house in Sitio Nabitasan. He alleged he was merely two arms’ length away, watching through a window, and saw the appellant stab the victim. The victim sustained sixteen wounds. The defense presented an alibi, asserting that the appellant was in a different barangay, about eight kilometers away, attending a birthday party at the time of the crime. The trial court and the Court of Appeals found Huntoria’s testimony credible and convicted the appellant.
ISSUE
The core issue is whether the guilt of the appellant was proven beyond reasonable doubt, hinging on the credibility of the lone eyewitness, Jose Huntoria.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED Custodio Gonzales, Sr. The Court found that Huntoria’s testimony failed to meet the test of credibility and could not sustain a conviction. The legal logic centered on the unreasonableness of the eyewitness account. Huntoria claimed to have witnessed a violent, prolonged murder from a very close distance without the assailants noticing him, which the Court found highly improbable. His presence at the scene was not explained, and his subsequent actions—failing to report the crime immediately and only coming forward after being summoned—cast doubt on his motives and truthfulness.
Furthermore, the Court emphasized that the prosecution must rely on the strength of its own evidence, not the weakness of the defense. The alibi, while generally a weak defense, was corroborated by other witnesses and became significant given the doubt cast on the prosecution’s evidence. The distance of eight kilometers between the crime scene and the appellant’s alleged location was considered sufficient to preclude his presence at the crime. The Court held that when the testimony of the sole eyewitness is riddled with incredulity and does not inspire belief, it cannot constitute proof beyond reasonable doubt. Consequently, the appellant was entitled to an acquittal.