GR 89117; (June, 1991) (Digest)
G.R. No. 89117 ; June 19, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO SALGUERO y LLANERAS, accused-appellant.
FACTS
The accused-appellant, Rodolfo Salguero, was charged with Robbery with Homicide. The prosecution evidence established that in the early morning of September 1, 1986, four armed men entered the Sevilla residence in Quezon City. The robbers, one of whom was positively identified by the victims Leonardo and Corazon Sevilla as Salguero, took Leonardo’s wallet containing P1,000.00. During the robbery, the Sevillas’ daughter, Alma, was stabbed and killed. The family jeep was also taken by the perpetrators as their getaway vehicle. Salguero pleaded not guilty, while his co-accused remained at large.
The defense presented an alibi. Salguero claimed he was in Olongapo City from August 25 to September 5, 1986, purchasing scrap materials, and thus could not have been at the crime scene. He alleged he was arrested on September 23, 1986, and subjected to police torture. The trial court convicted Salguero, sentencing him to reclusion perpetua and ordering him to pay damages.
ISSUE
Whether the prosecution evidence was sufficient to prove the guilt of the accused-appellant beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Salguero. The Court emphasized that a conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The constitutional presumption of innocence requires proof of guilt beyond reasonable doubt, which demands moral certainty. In this case, the Court found the prosecution’s evidence inadequate to meet this stringent standard. The positive identification of the appellant was deemed insufficient to overcome the presumption of innocence. While alibi is generally a weak defense, it need not even be considered when the prosecution’s evidence is itself weak, as it fails to discharge the required burden of proof. The Court concluded that the evidence did not establish moral certainty of Salguero’s guilt, creating reasonable doubt that must be resolved in favor of the accused. Consequently, the decision of the Regional Trial Court was set aside.