G.R. No. L-72025. June 30, 1988. PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS COLINARES Y SOLMERANO alias Caloy & ERNANI BASAYSAY alias Dominador Italia y Plofino, accused-appellants.
FACTS

Accused Carlos Colinares and Ernani Basaysay were charged with Murder for the killing of Armando Cardenas on November 29, 1981, in Quezon City. The prosecution alleged that during a neighborhood quarrel, Colinares, along with around thirty armed companions, mauled the victim inside the house of his uncle, Roberto Lopez. The victim fled but was chased, mauled further, and was seen bleeding and sprawled on the ground. Colinares then placed the injured Cardenas into a barangay service jeep. The victim’s relatives, Roberto and Trinidad Lopez, followed the jeep to the barangay hall, where they saw the bleeding victim inside with Colinares seated beside him. The victim pleaded for help, expressing fear of being killed by his companions. Trinidad was prevented from boarding the jeep by Colinares. The victim was later brought to a hospital and pronounced dead on arrival. The autopsy revealed fatal hacked and stab wounds.

ISSUE

Whether the guilt of accused-appellant Carlos Colinares for the crime of Murder was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the trial court’s conviction and acquitted Carlos Colinares. The prosecution’s evidence failed to establish his guilt beyond reasonable doubt. The Court found the testimony of the medico-legal expert, Col. Gregorio Blanco, critically significant. He testified that the victim’s body was already in full rigor mortis when he autopsied it at noon on November 29, 1981, indicating death had occurred more than twelve hours prior. This directly contradicted the prosecution’s timeline that the mauling and subsequent events transpired at around 10:00 A.M. that same morning. This inconsistency created a serious doubt regarding the very foundation of the prosecution’s narrative.
Furthermore, the Court found the evidence against Colinares to be purely circumstantial and insufficient to support a conviction. The prosecution witnesses did not see who inflicted the fatal wounds. The fact that Colinares was seen with the victim before his death, without more, does not conclusively prove he was the perpetrator. The chain of circumstances was not complete and did not lead to a singular, inescapable conclusion of his guilt. The failure to present other material witnesses, such as the Metrocom soldiers allegedly present or other jeep occupants, further weakened the case. In criminal cases, the burden is on the prosecution to prove guilt to a moral certainty. Any reasonable doubt must be resolved in favor of the accused. Consequently, Colinares was acquitted and ordered released. (Paras, J., with Yap, C.J., Padilla, and Sarmiento, JJ., concurring. Melencio-Herrera, J., dissented, believing the circumstantial evidence pointed to guilt for at least Homicide.)