GR L 24454; (June, 1968) (Digest)
G.R. No. L-24454 June 22, 1968
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALERIANO MANANGUITE @ ANOY, REYNALDO MORILLO @ REYNING and EDENCIO MONTANO @ EDEN, defendants-appellants.
FACTS
Defendants-appellants, police officers of Mondragon, Samar, were convicted of murder for the death of Perfecto Navarro. The alleged triggerman, Fidel Cerenado, eluded arrest. The conviction was based on the testimonies of two alleged eyewitnesses, Gregorio Navarro (brother of the victim) and Paciencia Gulariza Vda. de Silva. Their versions were that on the night of March 15, 1964, while Perfecto was at Paciencia’s house, Chief of Police Mananguite ordered, “Alright, you kill him now because he is already here,” prompting Fidel Cerenado to shoot Perfecto multiple times. The appellants denied involvement. The autopsy revealed the victim had consumed tuba. The next day, the victim’s widow and sister sought Chief Mananguite’s help. He investigated, and several witnesses, including Paciencia, gave sworn statements claiming they did not know who killed Perfecto due to the darkness. At trial, Gregorio’s testimony on the sequence of shots was contradicted by the medical findings, and Paciencia’s sworn statement given shortly after the incident was inconsistent with her later courtroom testimony.
ISSUE
Whether the prosecution proved the guilt of the defendants-appellants beyond reasonable doubt based on the testimonies of the alleged eyewitnesses.
RULING
No. The Supreme Court reversed the judgment of conviction and acquitted the defendants-appellants. The Court found the testimonies of the two key eyewitnesses lacking credibility and insufficient to establish guilt beyond reasonable doubt. Gregorio Navarro’s description of the shooting sequence was physically impossible and directly contradicted by the medico-legal report on the victim’s wounds. Paciencia Gulariza’s testimony in court was irreconcilably at odds with her sworn statement given before the municipal judge immediately after the incident, in which she stated she did not witness the shooting due to darkness and only heard gunshots. The presence of the municipal judge’s handwritten questions and answers on that sworn statement confirmed its voluntariness and reliability. The prosecution’s evidence failed to meet the required standard of proof beyond reasonable doubt.