G.R. No. 84715 October 17, 1990
The People of the Philippines, plaintiff-appellee, vs. Arnulfo Cendana y Reyes, accused-appellant.

FACTS

The case stemmed from the killing of Dominador Manongdo, who was found dead with a gunshot wound to the head in a ricefield in Sta. Barbara, Pangasinan, on November 24, 1986. Accused-appellant Arnulfo Cendana was charged with Murder “thru illegally possessed firearm.” The prosecution’s case relied heavily on police testimonies. After investigating, police officers, acting on information from unidentified persons that Cendana was seen carrying a gun, went to apprehend him without a warrant. They located him in a house in Dagupan City, arrested him, and recovered a homemade shotgun. The officers testified that Cendana admitted to the shooting after his arrest. The trial court convicted Cendana of Murder and sentenced him to reclusion perpetua.

ISSUE

The core issue is whether the prosecution proved the guilt of the accused-appellant beyond reasonable doubt, considering the admissibility and sufficiency of the evidence presented against him.

RULING

The Supreme Court reversed the conviction and acquitted the accused-appellant. The Court agreed with the Solicitor General’s recommendation for acquittal, finding that the evidence was constitutionally infirm and insufficient. The warrantless arrest was illegal as it did not fall under any valid exception under Rule 113; the police had no personal knowledge that Cendana had just committed the offense but acted merely on hearsay information. Consequently, the subsequent warrantless search and seizure of the shotgun were also illegal, being a fruit of the poisonous tree. The alleged extrajudicial admission was inadmissible, having been obtained while Cendana was under custodial investigation without the benefit of counsel, in violation of his constitutional rights.
With the exclusion of the inadmissible confession and the illegally seized firearm, the remaining evidence was insufficient to sustain a conviction. The paraffin test indicating gunpowder nitrates on Cendana’s hands was a solitary circumstance, insufficient under the rules on circumstantial evidence, which require a confluence of multiple proven circumstances leading to a moral certainty of guilt. The ballistic report merely stated the shotgun was serviceable but did not link it to the crime. The plausible defense explanation for the paraffin result—that he had fired an armalite at a party—remained unrebutted. Without an eyewitness and with only one unreliable circumstance, the prosecution failed to prove guilt beyond reasonable doubt.