GR L 5752; (March, 1911) (Digest)
G.R. No. L-5752, March 11, 1911
THE UNITED STATES vs. LORENZO SISON, FRANCISCO BILLADO, and HILARION DE LA CRUZ
FACTS
On the evening of February 26, 1909, Santiago Bolanon was fatally assaulted near his house in Sandayon. His daughter, Leona Bolanon, witnessed the attack. She testified that she saw three menLorenzo Sison, Francisco Billado, and Hilarion de la Cruztie up her father downstairs, bring him upstairs, and strike him with bolos. Leona claimed she armed herself, engaged Lorenzo, and during their fight, the blade of his bolo separated from its handle, leaving a hand-guard and ring on the ground. She further testified that she later overheard Hilarion discussing her father’s death. The prosecution’s case rested almost entirely on Leona’s identification and testimony. The defendants denied involvement and presented alibis.
ISSUE
Is the testimony of the lone eyewitness, Leona Bolanon, sufficient to establish the guilt of the accused beyond a reasonable doubt?
RULING
No. The Supreme Court reversed the trial court’s judgment and acquitted the defendants. The Court found Leona’s testimony inherently improbable and inconsistent with human experience, making it an insufficient basis for conviction. Key inconsistencies noted include: (1) her claim that the assault and her fight occurred inside the house, which conflicted with the natural evidence (the bolo parts were found outside) and the complaint filed by her brother-in-law, Esteban Ugaban, which suggested the assault happened outside; and (2) her failure to immediately identify the defendants (who were known to her) to Esteban when he arrived and when he went to report the crime, despite having ample opportunity to do so. The Court held that while a murder undoubtedly occurred, the lone witness’s testimony was too unreliable to sustain a conviction.
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