G.R. No. L-20153; June 29, 1967
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FULGENCIO BAQUIRAN, defendant-appellant.

FACTS

On April 29, 1959, in Tumauini, Isabela, Alberto Castillo was shot and killed while eating supper with his family. An information for murder was filed against Fulgencio Baquiran. The prosecution’s case rested primarily on the testimonies of the victim’s wife, Juanita Marilao, and daughter, Celedonia Castillo, who identified Baquiran as the assailant. They testified the area was lit by two kerosene lamps, enabling identification, and that Baquiran fired once. The defense presented an alibi, asserting Baquiran was in barrio Arcon, over six kilometers away, conducting an investigation into a theft from around 6:00 PM to 8:30 PM that evening, corroborated by several witnesses. Key prosecution witnesses, including Sgt. Venturina, Chief of Police Gumatay, and Dr. Laman, contradicted Juanita’s account. They testified that immediately after the crime, Juanita stated she could not recognize the assailants because it was dark or because their caps were tilted down. The police blotter entry also indicated non-recognition. Physical evidence indicated two gunshot wounds and two empty carbine shells were found. The trial court convicted Baquiran of murder and sentenced him to life imprisonment.

ISSUE

The central issue is whether the prosecution proved beyond reasonable doubt the identity of Fulgencio Baquiran as the perpetrator of the murder of Alberto Castillo.

RULING

The Supreme Court REVERSED the judgment of the trial court and ACQUITTED Fulgencio Baquiran. The Court found the identification by the prosecution witnesses unreliable. Juanita Marilao’s testimony was riddled with inconsistencies: she changed her account of the lighting from candles (in her sworn affidavit) to kerosene lamps; she claimed only one shot was fired contrary to medical and physical evidence of two; and her failure to warn her husband or immediately identify the assailant to authorities was contrary to natural human behavior. The testimonies of disinterested witnesses (Sgt. Venturina, Chief Gumatay, Dr. Laman, and Mateo Forto) established that Juanita did not recognize the assailant immediately after the crime. The defense alibi, corroborated by multiple witnesses and unchallenged by the prosecution as to the possibility of Baquiran being at the crime scene during the crucial period, gained strength in light of the weak and unreliable identification. The prosecution failed to meet its burden of proving guilt beyond reasonable doubt.