GR L 18661; (November, 1968) (Digest)
G.R. No. L-18661 November 29, 1968
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JOSE ALTO, ET AL., defendants-appellants.
FACTS
Two criminal cases were filed in the Court of First Instance of Nueva Ecija. In Criminal Case 4167, Jose Alto, Bienvenido Almuete, Melencio Gregorio, Melchor de Leon, Melencio Marcos, Pedro Paras, and Ismael Dungao were charged with multiple murder for an ambush on December 15, 1951, which resulted in the deaths of Cayetano Tangunan, Pedro Elvinia, and Simplicio Siazon. In Criminal Case 4181, Jose Alto, Melchor de Leon, Pedro Paras, Ismael Dungao, Melencio Gregorio, and others were charged with multiple frustrated murder for an ambush on November 12, 1950, which injured Mayor Eduardo L. Joson and his companions. The prosecution’s theory was that Jose Alto, a political rival of Mayor Joson who lost to him in the 1947 and 1951 mayoral elections, offered a P2,000 reward to Hukbalahap (HMB) members to kill Mayor Joson. After trial, the lower court convicted Jose Alto, Bienvenido Almuete, Melencio Gregorio, and Melencio Marcos in Criminal Case 4167, and Jose Alto, Ismael Dungao, and Melencio Gregorio in Criminal Case 4181. Only Jose Alto appealed to the Supreme Court, as the appeals of the other convicted defendants were withdrawn.
ISSUE
Whether the guilt of appellant Jose Alto for the crimes of multiple murder and multiple frustrated murder was proven beyond a reasonable doubt based on the evidence presented.
RULING
The Supreme Court ACQUITTED appellant Jose Alto. The Court found the evidence against him insufficient to establish guilt beyond a reasonable doubt. The case rested almost entirely on the uncorroborated testimony of prosecution witness Laureano Salvador, a self-confessed accomplice and former member of the Huk Tanggulang Bayan. Salvador testified that he attended a meeting where Huk commanders agreed to Alto’s offer of P2,000 to liquidate Mayor Joson, and that he later accompanied Isaac Francisco to receive the money from Alto and deliver it to the Huk commanders. The Court found Salvador’s testimony fraught with inconsistencies, improbabilities, and inherent weaknesses. It was uncorroborated on vital points, as the other witnesses (Toribio Garcia and Dominador Pineda) did not witness the alleged payment, and the alleged recipient commanders were dead or unavailable. The Court also noted that the testimony of accomplices must be received with utmost caution and requires strong corroboration, which was lacking. Furthermore, the political rivalry between Alto and Joson raised the possibility that the charges were politically motivated. The Court concluded that the evidence did not preclude the probability that the ambushes were part of the Huks’ own campaign against Mayor Joson, with which Alto may have had no complicity. The presumption of innocence prevailed.
