THE PEOPLE OF THE PHILIPPINES, vs. RODOLFO SALGUERO y LLANERAS, EMMANUEL MESINA y DATUIN, ET AL., accused,
- G.R. Number: G.R. No. 89117
- Promulgated: 1991-06-19
- Ponente: Gutierrez, Jr., J.
Doctrine
Affidavits taken ex parte are often incomplete and sometimes inaccurate; their probative value must be tested against in-court testimony and contradictions.
When evidence for the prosecution is inadequate or riddled with inconsistencies, the accused must be acquitted on the ground of reasonable doubt.
Facts
This is an appeal from the Regional Trial Court of Quezon City, Branch 92, which found Rodolfo Salguero guilty as principal of Robbery with Homicide and sentenced him to reclusion perpetua.
At trial the prosecution relied on witness affidavits and testimony; one witness (Corazon) had an ex parte affidavit but in open court affirmed its accuracy despite earlier inconsistencies.
The trial court found inconsistencies between the appellant's testimony and that of his witnesses and discounted testimony identifying another suspect (Otchok Salvador).
On appeal, the Court of Appeals found the prosecution's evidence inadequate and reversed, acquitting the appellant for reasonable doubt and ordering his release.
Issues
Whether the prosecution proved the guilt of the appellant beyond reasonable doubt.
Ruling
The Court held the prosecution's evidence inadequate to prove guilt beyond reasonable doubt, reversed the trial court's conviction, acquitted the appellant, and ordered his immediate release unless held for other charges.
Keywords
G.R. No. 89117, Robbery with Homicide, reclusion perpetua, moral damages, actual damages, amended information, conspiring together, confederating with and mutually helping one another, intent of gain, violence and intimidation on persons, Civil Code of the Philippines, pleaded not guilty, at large, guilt beyond reasonable doubt, positive identification, alibi, assignment of errors, Office of Solicitor General, acquittal of the appellant, judgment of conviction beyond reasonable doubt