G.R. No. L-2768

FACTS:
Nazario Vallesteros was convicted of robbery in an armed band for an incident occurring on May 4, 1904, at the parish house of Piddig, Ilocos Norte. He was sentenced to fourteen years and eight months of cadena temporal, ordered to return the stolen property or pay its value, and to pay costs. The conviction was based on circumstantial evidence, including: (1) testimony from the justice of the peace regarding a withdrawn statement from a preliminary investigation implicating Vallesteros; (2) testimony from a Constabulary sergeant that Vallesteros admitted participation but claimed he was forced; and (3) the discovery of a gun on Vallesteros’s property.

ISSUE:
Whether the evidence presented is sufficient to prove beyond reasonable doubt the guilt of Nazario Vallesteros for the crime of robbery in an armed band.

RULING:
No. The Supreme Court reversed the conviction and acquitted Vallesteros. The evidence was insufficient:
1. No eyewitness identified Vallesteros as a participant in the robbery.
2. The testimony of the justice of the peace regarding an implicating statement was inadmissible as the statement was not introduced in evidence and was subsequently withdrawn during the preliminary investigation.
3. The alleged admission to the Constabulary sergeant was inadmissible because it was induced by a promise of acquittal and was not spontaneous. Furthermore, the sergeant’s testimony was unclear and hearsay. Even if admitted, Vallesteros’s claim of being forced would exempt him from criminal liability under the Penal Code.
4. The gun found on his property was not proven to be the weapon used in the robbery.
The Court ordered his acquittal and the reversal of the lower court’s judgment, with costs de oficio.