G.R. No. L-21860 February 28, 1974
People of the Philippines, plaintiff-appellee, vs. Violeto Villacorte, et al., defendants. Crisanto Inoferio y Alindao alias Sante, defendant-appellant.

FACTS

The case involves the robbery with homicide of Chinese merchant Benito Ching on August 27, 1959. While walking home with his employees Pedro Libantino and Modesto Galvez, Ching was accosted by four men. One assailant, later identified as Violeto Villacorte, snatched a paper bag containing money from Ching and shot him, resulting in Ching’s death the following day. Initially, neither Libantino nor Galvez could identify the perpetrators to the Caloocan police on the night of the crime. However, in subsequent statements to the CIS, both identified Villacorte as the gunman. Villacorte, upon arrest, confessed and named his companions as “Roque,” “Fred,” and “Sante.”
The information was amended to include Crisanto Inoferio as “Sante.” The trial court discharged Roque Guerrero to become a state witness, acquitted Alfredo Handig (“Fred”), and convicted Villacorte, Marciano Yusay, and Inoferio. Only Inoferio pursued his appeal. The prosecution’s case against him rested primarily on the testimonies of eyewitness Modesto Galvez and state witness Roque Guerrero, who identified Inoferio as one of the men who held Galvez during the robbery.

ISSUE

Whether the prosecution proved the guilt of appellant Crisanto Inoferio for the crime of robbery with homicide beyond reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Crisanto Inoferio. The Court held that while the defense of alibi is inherently weak, it may prevail when the prosecution’s evidence is insufficient to establish guilt beyond reasonable doubt. The Court found the identification of Inoferio by the prosecution witnesses to be unreliable. Galvez failed to identify Inoferio during initial police investigations shortly after the crime, only doing so later in court, suggesting his identification may have been based on supplied information rather than personal recollection. The testimony of state witness Guerrero was deemed untrustworthy due to a possible motive for revenge, as Inoferio had pointed to Guerrero during a police lineup, which Guerrero might have misinterpreted as an attempt to implicate him.
Conversely, Inoferio’s alibi—that he was elsewhere at the time of the crime—was supported by corroborating testimony and remained unrebutted. The Court emphasized that alibi must be scrutinized with care and, in this instance, it sufficed to create reasonable doubt when juxtaposed with the prosecution’s weak and unconvincing evidence. The constitutional presumption of innocence therefore demanded an acquittal. Inoferio was ordered immediately released from detention.