G.R. No. L-74799. March 28, 1988.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. VIVENCIO TUAZON Y DIZON, defendant-appellant.

FACTS

The accused, Vivencio Tuazon, was convicted of murder and sentenced to death by the Regional Trial Court of Quezon City for the killing of Lolita Labia on December 19, 1984. The prosecution’s case hinged on eyewitness identification. Witnesses claimed a man alighted from a car with plate number NHZ-479, confirmed the victim’s identity, shot her, and fled in the same vehicle. Police investigation traced the car’s registration to Tuazon. A police line-up was conducted where four witnesses identified Tuazon as the gunman. Based on this, an information for murder was filed against him. The defense, however, presented a starkly different account. Tuazon claimed he was not the triggerman and asserted he had rented his car to a certain Victor Yago, Jr. on the day of the crime. The defense presented Yago himself, who testified and corroborated the car rental. More critically, the defense presented the sworn statements of Yago and another individual, Danilo Lim, wherein Lim confessed to being the actual shooter. The trial judge, however, disregarded this defense evidence, focusing instead on the initial eyewitness identifications.

ISSUE

Whether the guilt of the accused for the crime of murder was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the conviction and acquitted the accused. The Court found the evidence insufficient to establish guilt beyond a reasonable doubt. The legal logic centered on the unreliability of the prosecution’s evidence when weighed against the defense’s compelling alternative narrative. The positive identification by witnesses, who did not know Tuazon beforehand, was rendered doubtful by the defense’s presentation of a credible confession from another individual, Danilo Lim, admitting to the crime. This confession, being an admission against penal interest, carried significant weight. Furthermore, the corroborative testimony of Victor Yago, Jr. regarding the car rental provided a plausible explanation for Tuazon’s vehicle being at the scene, supporting his defense of alibi. The Court held that the possibility of mistaken identity was high, given the fleeting and startling nature of the incident. The trial court’s refusal to seriously consider this defense evidence demonstrated a lack of impartiality. Consequently, the prosecution failed to overcome the constitutional presumption of innocence. Moral certainty of Tuazon’s guilt was not achieved, necessitating acquittal. The Court also directed the Quezon City Fiscal to reinvestigate the crime to apprehend the true perpetrators.