G.R. No. L-39447 August 8, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VALENTIN SALANGOSTE, accused-appellant.

FACTS

The accused-appellant, Valentin Salangoste, was convicted of parricide for the killing of his wife, Victoria Adato, and sentenced to reclusion perpetua by the Court of First Instance of Northern Samar. The prosecution’s case was built on circumstantial evidence. Primitivo Basarte testified that in the early morning of August 27, 1973, Salangoste, armed with a bolo and torch, attacked him in his camalig. During the struggle, Basarte wounded Salangoste on the forehead before fleeing. Luciana Baluyot testified she later heard Victoria’s alarming shrieks from the direction of Basarte’s house and saw a torchlight moving around the area. Victoria’s body, bearing 16 wounds from a sharp instrument, was found in Basarte’s main house later that morning.
The defense presented a different narrative. Witnesses, including Basarte’s neighbor Emilio Irineo, testified that after being wounded, Salangoste went to Irineo’s house to challenge him to a fight, behaving like someone searching for his assailant, not like a man who had just killed his wife. The defense also presented witnesses who testified that Basarte had confessed to killing Victoria and another neighbor, suggesting Basarte was the actual perpetrator.

ISSUE

Whether the guilt of the accused-appellant for the crime of parricide has been proven beyond a reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Salangoste on the ground of reasonable doubt. The Court meticulously analyzed the conflicting evidence. While the trial court found the prosecution witnesses credible, the Supreme Court is not bound by such findings and may arrive at its own conclusions. The Court found the defense’s version of events to be more credible and in accord with ordinary human experience. The testimony of Emilio Irineo was particularly significant, as it established that immediately after the altercation with Basarte, Salangoste was behaving rationally—searching for the man who wounded him—and not like someone who had just committed a frenzied murder.
The Court applied the principle that when the prosecution’s evidence is circumstantial, it must be acted upon with great caution. The scales of justice must tip in favor of the accused when evidence is weighed. The defense successfully cast reasonable doubt on the prosecution’s narrative by presenting an alternative scenario where Primitivo Basarte, not Salangoste, was the killer, supported by witness accounts of Basarte’s alleged confession. The prosecution failed to negate this hypothesis beyond a reasonable doubt. Consequently, the constitutional presumption of innocence prevailed.