GR 83695; (September, 1989) (Digest)
G.R. No. 83695 September 15, 1989
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROY ALZAGA, accused-appellant.
FACTS
The accused-appellant, Roy Alzaga, was convicted of murder by the Regional Trial Court of Legazpi City for the killing of Alfredo Adique on January 9, 1984. The prosecution evidence established that on the night of the incident, the victim, his brother Vicente Adique Jr., and Ernesto Toledo were going to the Sawali Restaurant. At the restaurant’s parking lot, Alzaga called out to Adique. The two conversed for about thirty minutes in a seemingly friendly manner. As Adique turned to leave, Alzaga drew him back by the arm, causing them to face each other. Alzaga then shot Adique in the face with a .38 caliber revolver, causing his death hours later. Two eyewitnesses, Vicente Adique Jr. and Ernesto Toledo, positively identified Alzaga as the shooter.
The defense presented a different version. Alzaga claimed he was at the restaurant to collect a debt from the victim. An argument ensued, and the victim allegedly attempted to draw a gun. A struggle for the firearm followed, during which the gun accidentally discharged, hitting the victim. Alzaga asserted the shooting was an accident, not an intentional killing.
ISSUE
Whether the prosecution evidence proved the guilt of the accused-appellant for the crime of murder beyond reasonable doubt.
RULING
The Supreme Court acquitted the accused-appellant on the ground of reasonable doubt. The Court found the prosecution’s evidence insufficient to establish guilt to a moral certainty. While there were eyewitnesses, their testimonies contained inconsistencies regarding the distance from which the shot was fired. More critically, the physical and ballistic evidence supported the defense’s theory of an accidental shooting during a struggle. The trajectory of the bullet and the expert opinion that the gun could have been fired at a very close range aligned with the claim of a grapple. The Court emphasized that when inculpatory facts are susceptible to two interpretations—one consistent with guilt and another with innocence—the interpretation favoring the accused must prevail. The evidence did not conclusively rule out the possibility of an accident, thereby failing to overcome the constitutional presumption of innocence. Consequently, the decision of the trial court was reversed and set aside.