GR L 36020; (October, 1979) (Digest)
G.R. No. L-36020 October 30, 1979
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NAZARITO AQUINO, ROMEO CASIMINA and PEDRO CASIMINA, accused-appellants.
FACTS
The accused, Pedro Casimina, his son Romeo, and Nazarito Aquino, were convicted of murder for the shooting death of Benigno Pascua during a “pintakasi” (communal farming) in Kabacan, Cotabato. The prosecution’s case hinged on the testimonies of Benigno Pascua, Jr., the eight-year-old son of the victim, and two other witnesses, Pacifico Narvas and Romulo Pascua. The child testified he saw “Manong Itong” (Aquino) and “Manong Pat-ti” (Romeo Casimina) and a third unidentified person shoot his father from a cornfield. Narvas and Romulo Pascua claimed they saw three men fleeing after the shots; they identified Aquino and Pedro Casimina but not the third, who was Romeo. The trial court found the testimonies credible and convicted all three as co-principals, sentencing them to reclusion perpetua. Aquino later withdrew his appeal.
ISSUE
Whether the guilt of appellants Pedro and Romeo Casimina was proven beyond a reasonable doubt.
RULING
No. The Supreme Court reversed the conviction, acquitting Pedro and Romeo Casimina. The Court meticulously analyzed the prosecution evidence and found it insufficient to meet the required standard of proof beyond reasonable doubt. The testimony of Benigno, Jr., while compelling from a child, was scrutinized against his sworn statement given shortly after the incident, which contained inconsistencies regarding the number of gunshots and the sequence of events. More critically, the testimonies of the adult witnesses, Narvas and Romulo Pascua, were deemed unreliable. Their claim of identifying the fleeing assailants from distances of 80 and 100 meters, respectively, under the circumstances, was improbable and lacked the requisite certainty. The Court emphasized that while the defense of alibi presented by the appellants was weak, the fundamental principle remains that the burden of proof lies entirely with the prosecution. The weakness of the defense does not compensate for the prosecution’s failure to establish guilt with moral certainty. The evidence presented, when investigated as a whole, engendered reasonable doubt as it was uncorroborated and inconclusive. Therefore, the presumption of innocence must prevail.