G.R. No. 85043 June 16, 1992
The People of the Philippines, plaintiff-appellee, vs. Glenn Hatton, defendant-appellant.
FACTS
Accused-appellant Glenn Hatton was charged with murder for the death of Faustino Algarme on August 29, 1986, in Catarman, Northern Samar. The prosecution’s principal witnesses, Edgardo Ongue and Romeo Basierto, testified that during the town fiesta, while they and the victim were walking, a tall man tapped Algarme’s shoulder and stabbed him in the back with a knife. Ongue saw the assailant’s mestizo features but did not know him. Basierto chased the assailant and later claimed to recognize him as Glenn Hatton, a fellow resident. The victim died from the stab wound. Ongue identified Hatton at the police station two days after the incident after police pointed him out as the suspect. The defense presented an alibi, with Hatton testifying he was at a friend’s house from 6:00 PM to 10:30 PM that evening, a claim corroborated by two witnesses. He also stated he is left-handed. The trial court convicted Hatton of murder and sentenced him to reclusion perpetua.
ISSUE
The main issues raised by the appellant are: (1) whether his constitutional right to due process was violated due to alleged judicial bias; (2) whether the trial court erred in dismissing the significance of his being left-handed contrary to the witness’s account of a right-handed attack; (3) whether the identification of the appellant was valid given the lack of courtroom identification and the allegedly suggestive pre-trial lineup conducted without counsel; (4) whether the trial court erred in not crediting the defense evidence; and (5) whether guilt was proven beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Glenn Hatton on the ground of reasonable doubt. The Court held that while the trial judge’s active questioning was clarificatory and not indicative of bias, the prosecution’s evidence was insufficient. The witness Basierto’s sworn statement immediately after the incident failed to name the assailant, referring to him only as an unidentified tall man, which contradicted his later courtroom testimony of recognition. The prosecution witnesses did not positively identify Hatton in court; their identification was based solely on a pre-trial police station lineup deemed suggestive. The Court emphasized that the prosecution must rely on the strength of its own evidence, and with the exclusion of the pre-indictment identification and the lack of positive courtroom identification, the case against Hatton must fail. The defense of alibi, while weak, becomes relevant when the prosecution’s evidence is not strong.