GR L 66509; (April, 1985) (Digest)
G.R. No. L-66509. April 25, 1985.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO B. ALCARAZ and CRISPIN CANTUTAY (Deceased), defendant-appellant.
FACTS
The case originated from the murder of Arturo Aquino, who was found dead inside his car in Davao City on January 10, 1978. The initial police investigation led to the arrest of Crispin Cantutay, who executed an extra-judicial confession implicating a certain “Boy Luna.” Upon confrontation, Cantutay retracted his statement against Luna and instead pointed to one “Rolly de los Santos” as his accomplice. Police, consulting files from the Anti-Narcotics and Dangerous Drugs Unit (ANDU), obtained a picture of “Rolly de los Santos,” which led to the apprehension of Eduardo Alcaraz on February 6, 1978. Alcaraz, upon confrontation with Cantutay, allegedly broke down and admitted participation, leading to his extra-judicial confession and a subsequent re-enactment of the crime. Cantutay was later killed, and trial proceeded solely against Alcaraz, who was convicted of murder by the Regional Trial Court.
ISSUE
The core issue is whether the guilt of Eduardo Alcaraz for the crime of murder was proven beyond a reasonable doubt, considering the admissibility and sufficiency of the evidence against him, particularly his extra-judicial confession.
RULING
The Supreme Court reversed the conviction and acquitted Eduardo Alcaraz on the ground of reasonable doubt. The legal logic centered on the inadmissibility of Alcaraz’s extra-judicial confession and the lack of corroborating evidence to establish his guilt. The Court emphasized that the confession was obtained without the assistance of counsel, rendering it inadmissible under constitutional and legal standards. Furthermore, the prosecution failed to present any independent evidence to corroborate the confession, as the only other evidence, the re-enactment, was a direct product of the inadmissible confession.
Critically, the Court found a fatal discrepancy in the identity of the accused. Testimony from ANDU Chief Captain Gregorio Lazarraga established that “Rolly de los Santos” and Eduardo Alcaraz were two separate and distinct persons, with separate arrest records. This created reasonable doubt as to whether Alcaraz was indeed the individual implicated by the deceased Cantutay. With the exclusion of the invalid confession, the remaining evidence was insufficient to prove Alcaraz’s participation beyond a reasonable doubt. The Court reiterated the fundamental principle that it is better for the guilty to go unpunished than for an innocent person to be unjustly convicted, thereby mandating acquittal when such doubt exists.