G.R. No. L-30069 September 30, 1969
People of the Philippines, plaintiff-appellee, vs. Anastacio Bulawin, defendant-appellant.

FACTS

The defendant, Anastacio Bulawin, was charged with and convicted of murder for the shooting of Ciriaco Jimenez. The incident occurred around 12:30 a.m. on September 23, 1963, in Barrio Mabatao, Salvador, Lanao del Norte, during a barrio fiesta. Jimenez was shot in the back and died later that day. The trial court sentenced Bulawin to an indeterminate prison term. The Court of Appeals certified the case to the Supreme Court as the proper penalty was reclusion perpetua. The prosecution’s case relied primarily on three witnesses: Candido Autor (the alleged sole eyewitness), Sgt. Roberto Laurie (who spoke with the victim after the shooting), and Aniceto Dacalos (who also spoke with the victim). The defense presented an alibi, claiming Bulawin was at a different location attending to his car.

ISSUE

Whether the prosecution proved the guilt of the appellant beyond a reasonable doubt.

RULING

The Supreme Court reversed the judgment of conviction and acquitted the defendant. The prosecution’s evidence failed to establish guilt beyond a reasonable doubt. The testimony of the main eyewitness, Candido Autor, was inconsistent and unreliable, as he contradicted himself regarding whether he saw the actual shooting. The testimony of Sgt. Roberto Laurie was impeached by his prior sworn affidavit, which contradicted his court testimony about the victim identifying his assailant. The testimony of Aniceto Dacalos was also unreliable, as it contained an incomplete and suggestive identification. The defense’s alibi, while not conclusively proven, was supported by witnesses and created reasonable doubt, especially in light of the weak prosecution evidence. The constitutional presumption of innocence and the requirement of proof beyond reasonable doubt were not satisfied.