G.R. No. L-51858 January 31, 1985
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RICARDO CABRERA and LORETO SIPE, accused.

FACTS

The case stemmed from an incident on September 16, 1972, in Barrio Guinsangan, Norala, South Cotabato. Patrolmen Victor Poral and Felix Fellores were on duty at a dance when they responded to a report of a man being chased. They encountered accused Loreto Sipe armed with a firearm. After an exchange of gunfire where both Sipe and Fellores were wounded, appellant Ricardo Cabrera allegedly rushed from behind and stabbed Fellores with a pinuti, killing him. Cabrera was arrested days later. The prosecution primarily relied on the eyewitness account of Patrolman Poral and two extrajudicial confessions executed by Cabrera on September 19 and 21, 1972. During trial, Cabrera repudiated these confessions, claiming they were extracted through force and maltreatment. He presented an alibi, stating he was at the dance and then went home, hearing gunshots but not participating. The defense also presented Benjamin Maca, who testified that it was Andresito Sipe, Loreto’s brother, who stabbed the victim, not Cabrera.

ISSUE

The core issue for review was whether the guilt of appellant Ricardo Cabrera for the crime of Murder with Assault upon an Agent of a Person in Authority was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED Ricardo Cabrera on the ground of reasonable doubt. The Court found the evidence insufficient to sustain a moral certainty of guilt. Critical to this decision was the serious doubt cast on the voluntariness of Cabrera’s extrajudicial confessions. Dr. Arturo Pingoy’s medical certificate, dated September 30, 1972, detailed multiple, widespread injuries on Cabrera’s body, including infected incised wounds and abrasions from head to lower extremities. The prosecution failed to prove these injuries were inflicted after the confessions were taken, leaving the strong possibility they were used to coerce the statements. Furthermore, the Court found the testimony of defense witness Benjamin Maca credible. Maca positively identified Andresito Sipe as the actual assailant who stabbed the victim from behind, providing a plausible explanation for Patrolman Poral’s possible mistaken identification, as Poral was not acquainted with Cabrera. The natural motive for Andresito Sipe to aid his brother, contrasted with the absence of any established motive for Cabrera, further bolstered reasonable doubt. The Court also censured the municipal judge for failing to ensure Cabrera was physically examined before administering the oath for his confession, a procedural safeguard to prevent coerced statements. Consequently, the totality of these considerations created reasonable doubt, mandating acquittal.