G.R. Nos. L-88753-54 August 20, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTHONY KIDAGAN y PAQUITO and ROBERTO TULDIKAN, accused. ANTHONY KIDAGAN y PAQUITO, accused-appellant.

FACTS

The accused, Anthony Kidagan, was charged with the complex crime of Rape with Homicide. The prosecution’s case relied heavily on the testimony of Victor Gabaen, the victim’s boyfriend and an eyewitness to the crime. Gabaen testified that on December 4, 1982, while he and the victim, Paula Sagamla, were resting, a man armed with a bolo attacked him from behind, rendering him unconscious. Upon regaining consciousness, Gabaen saw the man having sexual intercourse with Sagamla. After the act, the assailant hacked Gabaen on the nape and left. Gabaen later found Sagamla dead with a hack wound on her neck. The trial court convicted Kidagan based on this testimony and sentenced him to reclusion perpetua.
However, the records revealed a critical inconsistency in the identification of the perpetrator. Initially, on December 5, 1982, Victor Gabaen executed a sworn statement positively identifying a certain Sario Ladangan as the person who hacked him and killed Paula Sagamla. A criminal complaint was filed against Ladangan. It was only after an extrajudicial confession was obtained from the accused, Anthony Kidagan, that the earlier complaint against Ladangan was withdrawn, and Gabaen began pointing to Kidagan as the culprit.

ISSUE

Whether the prosecution proved the guilt of the accused, Anthony Kidagan, beyond reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted Anthony Kidagan. The legal logic centered on the constitutional presumption of innocence and the prosecution’s failure to meet the burden of proof beyond reasonable doubt. The Court found the identification of the accused by the principal eyewitness, Victor Gabaen, to be irreparably unreliable. Gabaen’s initial, immediate, and sworn identification of another individual, Sario Ladangan, as the perpetrator created serious doubt about the accuracy of his subsequent identification of Kidagan. The prosecution offered no credible explanation for this drastic and material change in Gabaen’s testimony. When the testimony of the sole eyewitness on the identity of the assailant is fraught with doubt and inconsistency, it cannot sustain a conviction. The principle that an accused is presumed innocent until proven guilty mandates that when the evidence does not convincingly establish guilt, the presumption must prevail. Consequently, the evidence presented by the prosecution was deemed insufficient to overcome this presumption, leading to the acquittal of the accused.