G.R. No. L-3255 February 17, 1954
EL PUEBLO DE FILIPINAS, querellante y apelado, vs. JUAN FERNANDEZ Y OTROS, acusados y apelantes.

FACTS

The accused-appellants were convicted by the Court of First Instance of Pangasinan for robbery with homicide and sentenced to reclusion perpetua. The prosecution’s evidence sought to establish that on the morning of March 16, 1949, in Tayug, Pangasinan, Juan Noble and the four appellants agreed to rob the house of Alejandro Noble in Natividad. That evening, they traveled by carriage (carromata) driven by Victor Melendez, along with an Aglipayan priest and Claudio Pastores. They alighted near the Independent Church in Natividad. Juan Noble retrieved a “grease gun” he was keeping and gave it to Zacarias Sadang, who handed it to Juan Fernandez. The group proceeded to Alejandro Noble’s house, leaving Pastores in a field. Upon arrival, Juan Noble hid in a tobacco plantation, Juan Fernandez and Zacarias Sadang went up the house, Policarpio Rodriguez stood guard nearby, and Victorio Noveda remained at the foot of the stairs. The noise alerted Alejandro, who shouted for help and jumped out a window. Fernandez and Sadang entered the house, pointed a gun at Rosita Fernandez (Alejandro’s wife), and took her earrings worth P20. Responding to the shouts, Juan Dominguez arrived and was shot by Juan Fernandez, dying the next day. Initially, the victims (Rosita and Alejandro) stated in their affidavits that they did not recognize the robbers as their faces were masked and it was dark. However, during the trial, they claimed to have recognized the appellants. Juan Noble and Claudio Pastores, initially implicated, became prosecution witnesses. The defense presented an alibi for Juan Fernandez, claiming he was acting as a Royal Guard at a dance at the Tayug auditorium from 8:00 to 11:00 PM on the night of the crime, corroborated by witnesses.

ISSUE

Whether the guilt of the accused-appellants for the crime of robbery with homicide has been proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the judgment of conviction and acquitted the accused-appellants. The Court found the evidence for the prosecution insufficient to prove guilt beyond reasonable doubt. Key reasons included: (1) The serious inconsistencies between the victims’ initial sworn statements (Exhibits 1 and 2) immediately after the event—where they stated they could not recognize the perpetrators—and their subsequent trial testimonies where they claimed recognition. (2) The incredible and contradictory nature of Juan Noble’s testimony, including how he could witness details from a distance in the dark and his changing account about his role in preventing the robbery. (3) The improbability that the appellants would discuss their criminal plans in front of strangers like the priest and the driver. (4) The prosecution’s failure to have the carriage driver, Victor Melendez, identify the appellants as his passengers that night, giving rise to the presumption that his testimony would have been adverse to the prosecution. (5) The alibi defense, while generally weak, was deemed credible in this case as the crime location was eight kilometers away and the prosecution’s evidence was frail. The Court concluded that the evidence did not overcome the constitutional presumption of innocence.