GR 91716; (October, 1991) (Digest)
G.R. No. 91716, October 3, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SEVERINO CAMPOS y DELA TORRE, accused-appellant.
FACTS
An Information charged multiple accused, including Severino Campos, with Multiple Murder and Frustrated Murder for the hacking deaths of Rosendo Hilardes, Conchita Hilardes, and Santos Hilardes, and the serious wounding of Pablo Hilardes on May 25, 1986. Only Campos and two others were arrested and tried. The prosecution’s case hinged on the testimony of Macario Hilardes, a surviving son. He testified that an armed group entered their house, tied his parents, and took them outside where they were killed. Macario claimed he identified Campos because, earlier that day, a friend pointed out Campos as part of an armed group walking near a creek. Based on this, the trial court convicted Campos, sentencing him to three penalties of reclusion perpetua and an indeterminate penalty for frustrated murder.
ISSUE
Whether the guilt of accused-appellant Severino Campos was proven beyond reasonable doubt.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED Severino Campos. The Court found the evidence against him insufficient to establish guilt beyond reasonable doubt. The sole eyewitness, Macario Hilardes, did not actually witness the killings themselves. His identification of Campos as part of the group that entered the house was based on a prior, casual sighting from a distance earlier in the day, which is inherently unreliable for positive identification, especially under the stressful circumstances of the nighttime attack. The Court emphasized that the constitutional presumption of innocence must prevail unless overcome by proof beyond reasonable doubt. The trial court’s inference of conspiracy was deemed speculative, as no overt act by Campos in furtherance of a conspiracy was established by positive evidence. Notably, the Court found an inconsistency in the trial court’s logic: it acquitted co-accused Pablito Baynosa for lack of evidence, even though the same witness implicated him in the same manner as Campos. Since the evidence against both was identical and insufficient, the acquittal of Baynosa logically necessitated the acquittal of Campos. The prosecution failed to discharge its burden of proof.