GR L 57280; (May, 1988) (Digest)
G.R. No. L-57280 May 9, 1988
PEOPLE OF THE PHILIPPINES, petitioner, vs. COURT OF FIRST INSTANCE OF RIZAL, BRANCH IV, QUEZON CITY presided over by the HON. RICARDO P. TENSUAN, AND VICTORINO ROBILLOS, respondents.
FACTS
The prosecution charged Victorino Robillos and his brother Antonio with homicide for the stabbing death of Loreto Mente. After numerous postponements, the trial commenced over two years after the accused’s arrest. The prosecution presented only one eyewitness, Lilia Españo, who testified that she heard Antonio challenge the victim and saw both brothers attack him, with Victorino hitting the victim with a stone. On cross-examination, her testimony revealed contradictions regarding her vantage point and the lighting conditions. After the prosecution failed to present its other witnesses on a scheduled hearing date, the defense moved to have the case submitted for decision based on the evidence already presented. The trial court initially granted a final opportunity for the prosecution to present evidence but later, upon a verbal motion from the defense, reversed itself and terminated the presentation of evidence against Victorino.
ISSUE
Did the respondent judge commit grave abuse of discretion in issuing orders that terminated the trial and subsequently acquitted Victorino Robillos, thereby allegedly denying the State its right to due process?
RULING
The Supreme Court ruled that the respondent judge did not commit grave abuse of discretion. The core legal principle is that the prosecution must prove the guilt of the accused beyond a reasonable doubt. The lone witness’s testimony, replete with contradictions and doubts regarding the accused’s specific participation, failed to meet this quantum of proof. The trial court, having observed the witness firsthand, was in the best position to assess credibility and correctly found the evidence insufficient for conviction. Furthermore, the constitutional right of the accused to a speedy trial was violated by the prosecution’s protracted delays, which spanned over two years and involved multiple postponements. The State cannot, after such unreasonable delay, complain of being denied its day in court when it failed to diligently pursue the case. Finally, the judgment of acquittal is immediately executory and constitutes a bar to any further prosecution for the same offense under the rule against double jeopardy. The petition was denied.