GR L 54298; (January, 1982) (Digest)
G.R. No. L-54298. January 30, 1982.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GILBERT SESE y BULANTE, ET AL., accused, GILBERT SESE y BULANTE, defendant-appellant.
FACTS
On April 6, 1977, an intruder entered the room of Liberata Cabanas in Tondo, Manila, stole a suitcase, and, upon being discovered, stabbed her to death. Her nine-year-old daughter, Noralyn, witnessed the crime. Investigated just hours later, Noralyn stated she could not identify the assailant, describing only a masked man with a hat. Neighbor Zelda Puyod, in her initial statement on April 7, also reported seeing nothing. Police subsequently detained and released several Sese brothers after a failed lineup where Noralyn did not identify anyone.
Two months post-incident, both witnesses changed their accounts. On June 4, Zelda Puyod claimed she saw appellant Gilbert Sese climbing towards the victim’s room. Noralyn later identified Gilbert in a subsequent lineup, but the appellant testified that this identification was coerced, with an aunt physically guiding Noralyn’s hand to point at him. The prosecution relied on these belated identifications to secure a conviction for robbery with homicide in the Court of First Instance of Manila, sentencing Gilbert Sese to reclusion perpetua.
ISSUE
Whether the prosecution proved the guilt of appellant Gilbert Sese beyond reasonable doubt based on the identification evidence presented.
RULING
No. The Supreme Court reversed the conviction and acquitted Gilbert Sese. The Court, concurring with the Solicitor General’s Manifestation recommending acquittal, held that the identifications were unreliable and failed to establish moral certainty of guilt. The initial statements of the two key state witnesses, given closest to the crime, contained no identification of the appellant. Noralyn, who knew Gilbert as a neighbor, did not name him initially despite having no apparent reason for fear. Zelda Puyod’s claim of having seen the incident contradicted her first statement that she noticed nothing.
The Court found the subsequent, belated identifications inherently suspect. The dramatic change in testimony after two months, coupled with evidence suggesting coercion during the lineup, rendered the evidence untrustworthy. Inconsistencies, such as the witnesses’ conflicting descriptions of the assailant’s height, further weakened the prosecution’s case. The ruling emphasized that the burden is on the prosecution to prove guilt beyond reasonable doubt independently of the defense’s weakness. The identification evidence here was so shaky and wavering that it could not overcome the constitutional presumption of innocence, thereby warranting acquittal.
